If someone doesn't meet the standard after any kind of IR course I would suspect something seriously wrong. Either with the training or the student, but not the structure of the course. 40 hours of SE flying is probably double what most people actually need with good preparation. It's not like you're learning how to fly from scratch. You're taking skills that you already have, polishing them and combining them with instrument approaches and holds etc. In truth the only hard thing is the NDB hold and approach, master that and you've cracked it. ILS is a non-event.