Thanks for all the comments.
I would be interested to find out why you think PEARs should not be performed by internal auditors?
The reason for adding PEARs was to increase the value of audits. Internal audits were not finding many or any issues and the QMS appears to be quite mature, yet when you look at the KPI's it is clear that more work is needed. Having aligned the KPI's to the processes I now find that PEARs show the same as the KPI and give a tool to start to improve each process.
So much value starting to be added the "management" see value in audits again and are even investing in training for more auditors