PCM data blocks (command 67, IDs 0x00..0x7F) are not required. You can resolve all of them into "usual" commands.
The exact method of resolving those depends on how the data blocks are used:
- command 68 - resolves into "67 66 ii" commands where "ii" is 0xC0..0xFF
- commands 80..8F - resolves into "52 2A dd" (dd = data)
- commands 90..95 - these are the DAC stream commands and they are the most complicated
command 90 specifies what sound chip + register the data goes to
In general the PCM data blocks are just a way to optimize the VGM file sizes. If you want, you can do everything without them.