First of all, I absolutely agree with you about the external oversight, so that's not my discussion.
I wanted to clarify, because it seems to me that the point you're taking is in fact a “not following the law as written” point when you're saying people being placed in...when it's not one of the listed reasons. I just wanted to clarify from my reading of it, that, in fact, it can only be done on listed reasons.
The oversight piece is to make sure that it's followed.