And some standards (like Common Criteria) actually require you to bring your own FIPS-validated CSPRNG, which effectively makes a userspace CSPRNG unavoidable.
I wasn't aware that FIPS required your _entropy source_ to be validated in order for your library to be validated, though. BoringSSL, for example, just reads from RDRAND, getrandom(2), or /dev/urandom. Maybe the OS/CPUs it's certified for all have FIPS-validated entropy sources?