Configuration management dictates that each GEMS release have a unique release number. This is not done just for certification purposes but also for development, support and production purposes. When a request, whether it be a bug report, support question, or shipping request, is made it must be possible to uniquely identify the release of GEMS being referred to.
Therefore the only way to have "the export of data fall outside of a specific GEMS release" would be to make the export of data a separate program. This would entail a major amount of work since this program would to deal wit security, audit, versioning, and other issues that are already dealt with in GEMS. Therefore this is not a viable option.
Furthermore is it not states that are asking for export data and are not the states the people who certify the software? Therefore if a state requests changes, whether it is for export or otherwise, our response should be "if we implement these changes this we be a new release and you (the state) will need to certify it." It then becomes the states decision, not ours, as to whether to proceed.