I don’t think the question is “begged” at all. The implied answer to your question (are they competent to oversee third party) is no and that answer is supported by their own findings.
As written about here:
With an active ACP program manager and a “traveling inspector office” already in place one has to consider if these are staffed with correct people and / or funded sufficiently or staffed sufficiently to perform their duties properly.
The point of my post above is rather than create a new “center of excellence” just properly staff and support the ACP program manager and these traveling inspectors. Perhaps even with civil servants drawn from merchant seaman. A few Class / USCG oversight team interactions may have class reviewing their own standards.