You raise some common additional concerns that have been raised about TBL.
You are right - one does need to have sufficient time to design and think through the mechanics. It certainly is more time consuming than reviewing existing lectures and doing what you have already done - but ask someone who is building a course (or even a new PowerPoint presentation) from scratch - that takes time too.
And, making MCQs that are meaningful - not shallow also takes time. I think the issue of “teaching ourselves” needs to be addressed through helping the learners understand what is the purpose of the TBL process and how RATs are part of the clarification of concepts. Appeals might mean the MCQ is unclear - but better having the appeal than wasting class time arguing semantics and interpretations.
Ultimately an Educator does need to know if EACH learner has achieved the desired knowledge AND Skills to accomplish the end outcome - so sometimes additional strategies, skills development strategies and assessments are needed to ensure success. That doesn’t negate the value of TBL in the repertoire of learning strategies.
Thanks for adding issues to the discussion.