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Do I Think that the Universal Accreditation Act Signifies the End of Private Adoptions?

Do I think that the Universal Accreditation Act signifies the end of private adoptions?
Everyone has been asking me if the Universal Accreditation Act (UAA) will end private adoptions. For those of you who don’t know, the UAA applies the same stringent accreditation guidelines as the Hague Adoption Convention to adoption service providers who are working in Non-Hague countries.  According to State Department guidelines, an accredited primary provider is required in every intercountry adoption case (with a few rare exceptions). This has created a stir amongst those who are adoptive privately as they typically will not have engaged the services of a primary provider to assist with the placement.
I don’t think anyone has anything to worry about. The Immigration and Nationality Act and corresponding regulations specifically envisage and provide for situations where children are orphaned but no agency or entity ever has custody of them. Children who are deserted (the biological parents refuse to parent them) or whose parents have disappeared are considered orphans; so too are the children of sole and surviving parents.  Congress intended that United States citizens should be able to adopt orphans from overseas and emigrate them as immediate relatives.  If USCIS suddenly requires that an accredited child placing entity be involved in every independent or private adoption, then we are excluding from our definition of visa eligible orphans an entire class of children which Congress explicitly and purposely intended to include in this class of children.  Furthermore, existing regulations specifically prohibit children being placed in the custody of a child placing entity in anticipation of a particular adoption.  The State Department/USCIS is not going to/ cannot require an adoption service provider to make a placement in all orphan adoption cases. They can and will however require an accredited provider to do the home study and post placement follow ups.  
I called the State Department recently to confirm my theories on the UAA and was told that they haven’t actually formulated any policies on this yet and couldn’t provide guaidance at this time. Call me back State Department- I have lots of good ideas when it comes to intercountry adoption!