Six Unsigned Packets and a Request to Backfill

Refuse, clearly and in writing, without escalating the tone. Signing a record to indicate that a review occurred when it did not is falsification of a quality record. It is a materially different and more serious finding than a missing signature, and it would itself be reportable. The six packets would go from a documentation gap to evidence of deliberate misrepresentation, and every packet the reviewer has ever signed becomes questionable.

What to do instead:

• Where the underlying check can still be evidenced - physical seal numbers already match on both copies - re-perform the integrity verification now, and sign as the person who re-performed it, dated today, with the note "re-performed at audit; original not evidenced." That is accurate and closes the control gap.
• Where it cannot be re-performed, record the finding as an open nonconformity with a disposition. An open finding is survivable; a backdated signature is not.
• Never alter the original packet. Attach the re-performance note as a separate document so the historical record stays intact.

Document the exchange: a short, factual file note - date, time, who asked for what, what you declined, and what alternative you proposed. Send the same content to the manager as a follow-up email so there is a shared record and no dispute later about what was said. Keep the language neutral: "I can't sign for a check I didn't perform; here's what I can do by the deadline." Frame the alternative as meeting the 10-day deadline, because it does - re-performing and documenting takes hours, not weeks.

If the instruction is repeated after the written refusal, that is a management-interference issue and goes up the quality line, separately from the audit report.

Finding 1 - six unsigned packets. Minor documentation nonconformity, provided the seal numbers verify and the check can be re-performed. No score impact: the seal was intact and the session's chain of custody is otherwise evidenced. It becomes major only if the re-performance fails or if the pattern is concentrated in one center or one proctor, which would suggest the check is being skipped rather than mis-signed.

Finding 2 - 11 sessions during a lapsed recertification. Training-compliance nonconformity. It does not, by itself, invalidate any result: recertification status is a staff-competency control, not a property of the examination. But it is not nothing either. Review those 11 sessions' incident logs, roster completeness, and any candidate complaints, and compare their irregularity rate against the regional baseline. If they look like all the others, report as a compliance finding with a corrective action. If they cluster problems, expand the review.

Finding 3 - two names in one hand on a sweep log. Major, and potentially the most serious item in the audit. One person appears to have recorded another person's work. That is a potential falsification, not a clerical slip, and it sits in the same unsigned packet, which raises the question of whether the second review was skipped because the second person was never there. Treat as suspected falsification: preserve the original log, take handwriting exemplars only through the proper process, and interview the named proctors separately.

Referral. Finding 3's session goes for review, plus every session in the surrounding window where those two proctors are both named. Findings 1 and 2 do not go for score review on current evidence.

On the managers' "scheduling thing" comment: that is an explanation, not a control. If the schedule cannot accommodate recertification, the schedule is the defect.

Root cause, stated as control failures rather than as staff behaviour:

• Packets are filed without a completeness gate, so missing signatures are discovered only at quarterly audit.
• Two-person review is required but not scheduled, so the second reviewer is often absent at close.
• The training register is not checked against the scheduling system, so a lapsed proctor can be rostered.
• Supervisors are not required to verify that the person named on a log is the person who did the work.

Corrective actions (owner / due date):

1. Re-perform and document the six seal-integrity checks - reviewer - 5 business days.
2. Investigation of the sweep-log handwriting finding, factual report to PSI - quality lead - 10 business days, concurrent with the CAPA submission and flagged as open.
3. Pre-filing checklist signed by the person assembling each packet, with a supervisor spot check of 10% - center managers - 30 days.
4. Replace initials-only sweep logs with name, time, and area, countersigned by the second person present - operations - 30 days.
5. Automated block: a proctor with expired training cannot be rostered, or requires a documented exception approved by the regional manager - scheduling system owner - 60 days.
6. Recall and re-brief all proctors on the recertification date and 30-day advance notification - training coordinator - 30 days.

Effectiveness check at 90 days: audit a fresh sample of 20 packets, target zero missing signatures; confirm zero proctors rostered with lapsed training; confirm the two-proctor verification on sweep logs by matching names to the rosters for the sampled dates.

One more thing: put the recertification-date review for all nine proctors into the current audit cycle, because the sample of two may be a sample of nine.