Versus theoretical, our counter-ion results are frequently biased low. However, we see the same thing with GC-FID results from an outside testing agency. I haven't ever bothered looking into how the theoretical value is calculated (I'd presume it has to do with how many basic groups there are, as well as the concentration of acetic acid in the final solution before lyophilization).
The best way to determine if the bias is due to your methodology or due to your sample would be to find a secondary standard and see how much acetate you actually recover. I see this a lot in reports we get for similar sorts of tests from agencies we use. They use one reagent from one vendor to prepare their curve, and then inject another reagent from another vendor to test the curve (looking for something like 95-105% recovery of the secondary standard). We don't bother to do that here, but I've always thought it was a good practice.