Pretty much. Two lugs are back to back and installed vertically, the third is stacked horizontal. The two that are back to back are in full contact with the ground bar but the third one on top is only making contact with the lug and not the ground bar.
Actually they installed a total of five lugs. Two sets are stacked back to back and mounted parallel to each other. The fifth lug is mounted perpendicular and each of the two holes in the lug is shared with the vertical lugs. They are in a "H" form, if that helps. The top lug only makes contact at the bolts holding all of the lugs to the bar, but only the vertical lugs are in full contact.
Is this a violation to NEC or any standards?