no....this sounds reasonable. I'm not up on my non-radar procedures, but in a radar enviroment an aircraft only needs to validate his mode C readout with ATC upon initial contact with the approach control facility (for example, climbing out of an airport). After that he is only expected to read back any assigned altitude.
In a non-radar enviroment or when mode C is inop or unreliable, pilots are usually instructed to "report reaching" an assigned altitude since there is no mode C readout to go on. Also during a climb or descent, a pilot may be instructed to "report leaving..." an altitude.
Ex: "Conquest niner lima charlie descend and maintain four thousand, report leaving niner thousand..."
The term "shall" indicates a mandatory procedure, and I'm not sure what the AIM says about altitude reporting in a non-radar enviroment but I'm sure it is addressed. As far as I know though, none of this stuff is new.