80 PLUS is a great program its there for us the consumers not an advertising tool for companies that exploit it for profit.
The 80 Plus program is open to exploitation and until its testing methodology is changed I can't see things changing!
Send us a power supply, we'll test it at an unrealistic working temperature (25 deg C I think), pay us some money and if it meets your specification we'll issue a certificate if it meets your claimed efficiency.
We won't police the certificate by testing future power supplies at random so feel free to send us your best performing power supply after batch testing to find the best or dare I say feel free to slightly tweak one it doesn't matter.
I'm fairly confident the leaders in ATX power supply manufacture/supply wouldn't stoop so low otherwise they wouldn't release their power supplies for review but I'm sure there are some that take advantage.