Currently, the way the 4th level ability is written, a cleric can make for itself any skeleton/zombie it wants because a base body isn't needed like the animate dead spell. This means you can have a Pseudonatural Paragon Half-fiend Ogre Skeleton at 4th level.
Currently, the way the 4th level ability is written, a cleric can make for itself any skeleton/zombie it wants because a base body isn't needed like the animate dead spell. This means you can have a Pseudonatural Paragon Half-fiend Ogre Skeleton at 4th level.
Call Undead is the 8th-level ability; I agree, it could use some limitations placed on it.
That said, I'm almost of a mind to say a GM that allows the player of an 8th-level character use material from the Epic Level Handbook deserves what he or she gets. Almost.
My bad on the level designation, though it's still bad at that level, or virtually any level. While a DM might disallow such, that doesn't remove the actual flaw in the rules, which needs to be done. If we can have it summon a skeleton without any templates, other than the skeleton one, then it should be good.