Maintenance Functions Discussion (CFR 145.217)

In the industry there seems to be a debate on whether certified vendors should be included on an organization's maintenance function list; seems that different people within the FAA have different takes on this too. Here is my going down the rabbit hole adventure with this, so I'd like to see if others agree, or if I'm viewing it wrong.

-CFR 145.217 (A) Essentially gives permission to a repair station to outsource a maintenance function, and what is required on it.
-CFR 145.217 (B) Discusses requirements for using a noncertificated person....
-CFR 145.217 (C) Repair station can't over tag a part.

-AC 145-9A states it is only a maintenance function where the repair station extends its privilege's for return to service.

-Order 8900.1 Vol. 6 Ch. 9, Sect. 23 subsection C "Note: If the person (contractor) performing the contracted maintenance function is authorized under 43.7 and provides approval for return to service under 43.9, this would not require FAA approval, and is not considered a contracted maintenance function."

My interpretation from this would be that no, a certified maintenance provider should not be considered a maintenance function. For example, overhauling of a thrust reverser requires actuators to be sent out. We will receive those back with 8130s and install them. We cannot do an inspection on those actuators and assign our own 8130 per CFR 145.217(c) and thus, we're not extending our repair station privilege's to them. Please leave opinions or additional references.

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