From this, I think by asking the question you will struggle to get an answer from the NAA to confirm that a MCF is not required if there is option for it to be carried out. This effectively rules their 'get out of jail' card if you had in writing an interpretation of the regulation which deemed it not to be necessary (the MCF) and then it was later found to be non compliant.
This highlights a greater problem across all areas of EASA regulation when it comes to the poor quality of service from NAA's. From experience dealing with the UK CAA and lack of experienced subject matter experts their seems to be hesitation in actually confirming / backing up the rules in which they are enforcing.
Inconsistency across member states also adds to the problem.
Ultimately, if you are acting diligently with regards to compliance and are able to justify procedures which have been submitted/approved IAW the regulation, you can go back to the NAA whom approved the particular manual (CAMME etc.) - just my take on it.
Maybe then they will advise otherwise.