When e-Learning first came out, the shop I was working for refused to allow it. After awhile, it allowed it on an experimental basis with a couple of instructors. The results were so good that they allowed it for anyone. My experience was that it was maybe the 12th such student that finally missed a question on the final exam for me. Eventually the shop required it for all students.To be clear, I understand the e-learning saves instructor's time, and lets them focus on hands-on, and that agencies provide some level of (debatable) quality control.
I left that shop shortly after that for unrelated reasons and went to a different shop. At the second shop, I went through the full sequence again. That shop now does nothing but e-Learning because the students learn the content so much better that way.
There's a lot to be said for such an idea. When I decide I need a golf lesson, it is a lot like this. I have advocated similar approaches in the past for simple skill improvement.There are a few ways to approach this, but I think a decent start would be tutoring. Sure, you don't get a certification card, but I personally don't take classes for some certification card or achievement. Perhaps have a session focused on finning techniques, bouyancy, or other similar specific skills. You could even do things like bi-weekly or weekly group classes, where you go over random intermediate skills. Perhaps offer enough of a discount for the people who show up to every class, to incentivize attendance even for those who already know the skills covered. Instructors could probably make more money, while students are also paying less.
Here's where the comparison breaks down. The golf instructor is not teaching you skills that could result in your death. The golf instructor will not be sued if you keel over and die while working on your putting skills.
Years ago another instructor and I independently developed a workshop much like you describe. When we learned that we had each done it, we conferred and made the workshops identical. Then he got advice from an attorney telling him to stop doing it. He said that if something--anything--were to happen to the student during a session, he could be sued. In that suit, the burden would be on him to prove that whatever he was doing was safe and within standard instructional practices. He would be on his own in this. If he were instead teaching an agency-approved program, he could still be sued, but he would not have to prove that what he was teaching was safe. The fact that the agency approved it would mean it was within standard instructional practices. His agency would join in his defense.
So he got the workshop approved by PADI as a distinctive specialty, and I joined him in doing that. It is essentially the same workshop as before, but every bit of it has now been examined by PADI experts and given the seal of approval. I have also had a course called Understanding Overhead Environments approved by PADI. The goal of the class is to explain the differences between various overhead environments so they can see why it may be OK for them to go through a simple coral swim-through but not a cave. Getting that approved by PADI was not easy; you can bet every word in that curriculum was scrutinized to make sure I was not teaching anything dangerous. I would not dream of teaching such a course without agency approval.
Just to give an example, let's say I am tutoring you and decide that the old "ditch and don" exercise would be a good learning experience for you. I have you go to the bottom of the deep end end of the pool, take off all your gear, swim to the surface, then dive down to retrieve your gear. That used to be a common experience in scuba classes. So you go down to the bottom, ditch your gear, and go to the surface, but you hold your breath on the way up and die from a gas embolism. When I am sued, the plaintiff's lawyer will show that pretty much all agencies have dropped that exercise because they believe it is too dangerous, so I will have to convince a jury that my belief in the safety of that exercise is superior to the judgment of pretty much all the agencies in the world. If instead I had made that part of the curriculum that I submitted to my agency for approval, they would have required me to take it out and told me why.