Anyone know if there is a time limit for getting FSDO to add type rating on civilian equivalent to military aircraft?

The SAT FSDO inspector I worked with to get my CFII etc under MCI said I could not get a Lear 35 type put on my ATP because I did not have a C-21 check ride within the last 12 months.

A type rating never expires...so why would there be a time limit if we have good documentation of the PIC time?