SFC Rob a simple answer without getting into specifics on why or why not you should write the NCOER's is:
Yes DA keeps track, regulation says that the Senior Rater is the one responsible for the whole process of the NCOER's being submitted so ultimately he is supposed to have the "why" answer. Realistlcally we both know that crap rolls down hill but it shouldn't reflect bad on you. Furtherly, some installations have what is called the Soldier Welfare Forms (SWF) this is where the CG of the post gets briefed on issues going on by units of Soldier stuff like NCOERs being submitted late and this is where your Chain of Command will have to explain why this evaluation is late and it will invlove all parties including S1 for not pushing hard enough to get these NOCER's done in a timely manner. This data usually gets pushed by G-1.