Wow. Small of back carry with no holster. That wouldn't fly with me either if that was my wife's preferred method of carry. I can't believe that would have been a sanctioned and approved method during her days as an MP either.
There are plenty of stories out there of people shooting themselves using no holster with pistol shoved in a waistband. Plaxico Burress comes to mind.
You might try suggesting the Raven Vanguard. It basically covers the trigger guard and that's it. It's attached to the pants with a drawstring and the "holster" comes off the trigger guard on the draw. If she would move to something like that it would give you at least some peace of mind.
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In fact you can find them for around $20. Just order one for her as a "gift."