That's a valid concern, but given that this is a process where an adult has to stand outside the door to observe a child who is typically in severe distress, it

That's a valid concern, but given that this is a process where an adult has to stand outside the door to observe a child who is typically in severe distress, it seems like mandating adherence to documentation requirements is both important and something they can make time for. There's an upper limit to how much paperwork it will generate.