That does seem most likely. The putative insider blog post about the production incident essentially said the same thing: the contractors/managers were exploit

That does seem most likely. The putative insider blog post about the production incident essentially said the same thing: the contractors/managers were exploiting a loophole to avoid recording the work in such a way that it would trigger a required review step (or somesuch, I forget the details). Not a big leap from there to "didn't get recorded at all", and from there to "lots of other stuff isn't recorded either". Boeing is in so, so much trouble here.