441 G St. N.W.

Washington, DC 20548

May 16, 2013

The Honorable Arne Duncan

Secretary

U.S. Department of Education

K-12 Education: States’ Test Security Policies and Procedures Varied

Dear Mr. Secretary:

Student results on statewide assessment tests required under the Elementary and Secondary 

Education Act of 1965 (ESEA), as amended, are used to measure students’ proficiency in core 

subjects, hold schools accountable for student achievement, and make key decisions, such as 

determining which low-performing schools should receive targeted interventions in order to 

improve student achievement. Therefore, it is critical that these results be valid and reliable. 

However, in recent years, instances of cheating by educators on state assessments have 

surfaced, undermining the integrity of the test results. For example, 82 educators in 30 Atlanta

schools confessed to improperly raising scores on state tests administered in the 2008-09 

school year. According to a district attorney press release, there were 35 indictments resulting 

from this investigation. Effective and rigorous assessment security policies, when properly 

implemented, can help prevent and detect cheating and other testing irregularities, but GAO’s 

prior work on the implementation of assessments showed that one of four states judgmentally 

selected for review relied on inadequate security procedures that could negatively affect the 

validity and reliability of their assessment systems.1

 

In 2010, the Council of Chief State School Officers (CCSSO) and the Association of Test 

Publishers (ATP) published a set of voluntary best practices for states and testing companies to 

use to strengthen the implementation of state assessment programs. Their publication includes 

best practices in six categories related to the security of paper- and computer-based tests.2

However, it is not known whether states have included these practices in their security policies 

and procedures or what additional efforts states have under way to detect and prevent cheating 

or other irregularities. 

Because state assessments—which the U.S. Department of Education (Education) has 

supported with over $2 billion since 2002—serve as the basis for school accountability and 

allocation of resources for targeted interventions, we prepared this report under the authority of 

the Comptroller General to conduct work on GAO's initiative.

3 Our objectives were to determine: 

 

1 GAO, No Child Left Behind Act: Enhancements in the Department of Education’s Review Process Could Improve 

State Academic Assessments, GAO-09-911 (Washington, D.C.: Sep. 24, 2009). 

2 The Council of Chief State School Officers and the Association of Test Publishers, Operational Best Practices for 

Statewide Large-Scale Assessment Programs (Washington, D.C.:, 2010). 

3

 See 31 U.S.C. § 717(b)(1).
Page 2 GAO-13-495R Test Security Leading Practices

1) the extent to which states’ policies and procedures include leading practices to prevent 

testing irregularities, 

2) what oversight states use to help ensure that districts and schools are following test

security policies and procedures, and how often cheating by school officials was 

identified as part of this oversight, and 

3) what sources of information or assistance states rely on for test security issues and what 

additional assistance would be useful. 

Scope and Methodology

To address our objectives, we designed and administered a web-based survey of testing 

administrators in the 50 states and the District of Columbia.

4 We conducted our survey from

November 2012 to January 2013, and received a response rate of 100 percent. We relied on 

the Operational Best Practices for Statewide Large-Scale Assessment Programs guide as a 

basis to design the survey. The survey included questions about each state’s assessment

program generally, as well as more specific questions about policies and procedures related to

test administration, training, and states’ oversight of assessment security policies and 

procedures for computer-based assessments.

5 We also collected information on states’ 

oversight activities and the extent to which states detected instances of cheating by school 

officials. 

To inform the survey, we conducted pretests with testing officials from four state educational 

agencies. We also conducted site visits and semi-structured interviews with state educational 

agencies and school districts in two states—Tennessee and Virginia. These states reflected a 

range of districts (e.g., urban and rural), use of computer-based assessments, and alleged or 

confirmed incidences of cheating. To further inform the survey, we reviewed relevant documents 

from Education and interviewed Education officials and representatives from the Council of 

Chief State School Officers, the Council of Great City Schools, American Association of School 

Administrators, and the Association of Test Publishers. We also interviewed officials from one 

test security company, Caveon Test Security, and individual test publishers, such as 

CTB/McGraw Hill and Measured Progress. In addition, we analyzed relevant federal laws. We 

did not analyze or verify information pertaining to state laws, policies, or procedures; therefore, 

all such descriptions of state laws, policies, or procedures were obtained from survey 

responses.

We conducted our work from March 2012 to May 2013 in accordance with generally accepted 

government auditing standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and 

conclusions based on our audit objectives. We believe that the evidence obtained provides a 

reasonable basis for our findings and conclusions based on our audit objectives. 

Summary

In summary, our nationwide survey of state assessment directors indicates the following:

• According to our survey, all states reported that their policies and procedures included 

50 percent or more of the leading practices to prevent test irregularities in the following 

 

4 Throughout the report we refer to the District of Columbia as a state.

5 Our survey did not examine state or local implementation of these test security policies.
Page 3 GAO-13-495R Test Security Leading Practices

five areas—security plans, security training, security breaches, test administration and 

protecting secure materials. Additionally, of the 28 states that administered computerbased assessments, the majority reported including half or more of the leading practices 

in computer-based testing. However, states varied in the extent to which they 

incorporated elements of certain categories of leading practices. For example, 22 states 

reported having all of the leading practices for security training, but four states reported 

having none of the practices in this category. Although state officials reported having a 

variety of security policies and procedures in place, many reported feeling vulnerable to 

cheating at some point during the testing process. 

• States reported using various tools, such as statistical analyses of student data, 

monitoring, and audits of testing procedures, to oversee districts’ implementation of test 

security policies and procedures, and most states have used this oversight to identify 

cheating in recent years. According to the state officials we surveyed, these oversight 

tools detected potential cheating by school officials in school years 2010-11 and 2011-

12. For example, officials in 40 states reported allegations of cheating in the past two 

school years, and officials in 33 states confirmed at least one instance of cheating.

Further, 32 states reported that they canceled, invalidated, or nullified test scores as a 

result of cheating.

• States reported receiving assistance with test security from several sources, with testing 

contractors being the most frequent source of support. States also identified areas 

where additional assistance with test security would be useful. In particular, officials from 

the majority of states reported that it would be very or extremely useful if Education 

gathered and disseminated information on best practices in test security. After our 

survey was administered, Education released a report—consisting largely of the 

opinions of experts and practitioners—that discussed best practices and policies related 

to testing integrity.6

 

Concluding Observations 

As more information about leading practices in test security is developed and disseminated, 

states will have improved access to the tools they need to develop strong policies and 

procedures in test security, and reduce their vulnerability to cheating on assessments. In 

particular, as more states begin using computer-based assessments—which may address some 

vulnerabilities of paper-based assessments, but may also create new ones, such as computer 

security breaches—additional guidance and oversight will be key to ensuring that appropriate 

policies and procedures are adopted by schools to address these new vulnerabilities. 

Although the risk of cheating on statewide assessments can never be completely eliminated, 

implementation of strong policies and procedures for preventing cheating, combined with robust 

oversight and detection by states, can greatly improve the integrity of test results. Without these 

measures, there is a higher risk that decisions based on test results may be faulty, and lead to 

damaging results, including failing to identify and provide resources for underperforming schools 

and students most in need of academic support.

Agency Comments

We provided a draft of this correspondence to the Department of Education for review and 

comment. In its written comments, reproduced in enclosure III, Education complimented GAO’s 

 

6 U.S. Department of Education, Institute of Education Sciences, National Center for Education Statistics, Testing 

Integrity Symposium: Issues and Recommendations for Best Practice (Washington, D.C.: 2013). 
Page 4 GAO-13-495R Test Security Leading Practices

efforts to describe the test security policies and procedures reported by states. Education also

recognized the remaining work that will be necessary to ensure test security in light of states’ 

efforts to implement new assessments aligned with college- and career-ready standards. 

Further, Education stated that it would continue to share best practices with states to reinforce 

the importance of test security and integrity.

In addition to Education, we are sending copies of this correspondence to the appropriate 

congressional committees. We will also make copies available to others on request. This

correspondence is available at no charge on the GAO website at http://www.gao.gov. 

If you or your staff members have questions about this correspondence, please contact me at 

(206) 287-4809 or calboml@gao.gov. Contact points for our Offices of Congressional Relations 

and Public Affairs may be found on the last page of this correspondence. Key contributors to 

this correspondence were Scott Spicer, Assistant Director; James Bennett; David Chrisinger; 

Paul Desaulniers; Alex Galuten; Danielle Giese; Jamila Kennedy; Jean McSween; Anna Maria 

Ortiz; Salvatore Sorbello; and John Townes. Also contributing to this correspondence were 

Lucas Alvarez; Amy Anderson; Deborah Bland; Jason Palmer; and Ashanta Williams.

Sincerely yours,

Linda M. Calbom

Western Regional Director 

Enclosures (3)
Enclosure I: Briefing Slides

Page 5 GAO-13-495R Test Security Leading Practices

K-12 EDUCATION: States’ Test Security 

Policies and Procedures Varied

Briefing for the Secretary of Education

For more information, contact Linda M. Calbom, (206) 287-4809 or calboml@gao.gov. Page 1

Enclosure I: Briefing Slides
Enclosure I: Briefing Slides

Page 6 GAO-13-495R Test Security Leading Practices

Overview

• Introduction

• Research Objectives

• Scope and Methodology

• Summary of Findings

• Background

• Findings

• Concluding Observations

Page 2
Enclosure I: Briefing Slides

Page 7 GAO-13-495R Test Security Leading Practices

Introduction

• Statewide tests (or assessments) are used to measure students’ performance in core 

subjects, hold schools accountable for student achievement, and make key decisions, 

such as targeting interventions to underperforming schools. Thus, it is critical that test 

results be valid and reliable. 

• However, in recent years, reports of school officials cheating on statewide 

assessments have surfaced in districts across the country, undermining the integrity of 

test results. For example:

• In 2012, California invalidated scores from 23 schools as a result of cheating by 

school officials, according to a local media report.

• In Atlanta, Georgia, 82 public school teachers and principals admitted to cheating 

on tests administered during the 2008-09 school year. According to a district 

attorney press release, there were 35 indictments resulting from this investigation.

• Similar allegations were also investigated in other states; for example, Illinois,

Maryland, Pennsylvania, Texas, and Washington, D.C.

Page 3
Enclosure I: Briefing Slides

Page 8 GAO-13-495R Test Security Leading Practices

Introduction (cont.)

• GAO’s prior work on state assessments—which addressed challenges states 

face with implementing valid and reliable assessments and the U.S. 

Department of Education’s (Education) oversight of assessment 

implementation—showed that one of four states judgmentally selected for 

review relied on inadequate security procedures.* 

• Effective test security policies and procedures, when properly implemented, 

can help prevent and detect cheating and other irregularities that can 

undermine the validity and reliability of state assessments.

Page 4 *GAO, No Child Left Behind Act: Enhancements in the Department of Education’s Review Process Could Improve State Academic Assessments, GAO-09-911 

(Washington, D.C.: Sep. 24, 2009). 
Enclosure I: Briefing Slides

Page 9 GAO-13-495R Test Security Leading Practices

Research Objectives

We prepared this report under the Comptroller General’s authority* to 

conduct work on GAO's initiative because reliable state assessments serve 

as the basis for school accountability and allocation of resources for targeted 

interventions. Our objectives were: 

1) To what extent do states’ policies and procedures include leading practices to 

prevent testing irregularities?

2) What oversight do states use to help ensure that districts and schools are 

following test security policies and procedures, and how often was cheating 

by school officials identified as part of this oversight?

3) On what sources do states rely for information or assistance with test security 

issues and what additional assistance would be useful?

Page 5 *See 31 U.S.C. § 717(b)(1). 
Enclosure I: Briefing Slides

Page 10 GAO-13-495R Test Security Leading Practices

Scope and Methodology

• We conducted a nationwide survey of state testing administrators to 

determine the extent to which their policies and procedures included leading 

practices in test security.* 

• We used the Operational Best Practices for Large-Scale Statewide 

Assessment Programs** as a basis to design the survey and conducted 

pretests with testing officials from four state educational agencies.

• The survey asked questions on six categories of leading practices 

identified in the best practices guide—security plans, security training, 

security breaches, test administration, protecting secure materials and 

computer-based testing. The survey also included questions about state 

oversight and procedures and the extent to which oversight activities 

detected cheating. 

• We conducted our survey from November 2012 to January 2013, and 

received a response rate of 100 percent.

Page 6 *Our survey did not examine state or local implementation of these test security policies.

** The Council of Chief State School Officers and the Association of Test Publishers, Operational Best Practices for Statewide Large-Scale Assessment Programs (Washington, D.C.: 

2010).
Enclosure I: Briefing Slides

Page 11 GAO-13-495R Test Security Leading Practices

Scope and Methodology (cont.)

• To inform the survey, we conducted site visits and semi-structured interviews with state 

educational agencies and school districts in two states—Tennessee and Virginia—that 

reflected a range of districts (e.g., urban and rural), use of computer-based 

assessments, and alleged or confirmed incidences of cheating by school officials. 

• To further inform the survey, we reviewed documents and interviewed officials from 

Education, national education organizations, test publishing companies, and one test 

security company. We also analyzed relevant federal laws. We did not analyze or 

verify information pertaining to state laws, policies, or procedures; therefore, all such 

descriptions are taken from survey responses.

• We conducted our work from March 2012 to May 2013 in accordance with generally 

accepted government auditing standards. Those standards require that we plan and 

perform the audit to obtain sufficient, appropriate evidence to provide a reasonable 

basis for our findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and conclusions 

based on our audit objectives.

Page 7
Enclosure I: Briefing Slides

Page 12 GAO-13-495R Test Security Leading Practices

Summary of Findings

• All states reported including at least 50 percent of the leading practices in test security into 

their policies and procedures. However, states varied in the extent to which they 

incorporated certain categories of leading practices.* For example, 22 states reported 

having all of the leading practices for security training, but four states had none of the 

practices in this category. Despite having reported that they have various leading practices 

in place to mitigate testing irregularities and prevent cheating, many states reported feeling 

vulnerable to cheating at some point during the testing process. 

• States use several tools to oversee test security, including monitoring, audits of testing 

procedures, and analyses of test data. As a result of these oversight activities, 40 states 

detected potential cheating during the past two school years and 33 states confirmed at 

least one instance of cheating. Further, 32 states reported canceling, invalidating, or 

nullifying test scores from individual students, schools, or districts because of suspected or 

confirmed instances of cheating by school officials.

• States relied on several sources for assistance with test security issues and identified 

additional areas where assistance from Education would be useful. Subsequent to our 

survey, Education issued a report—consisting largely of the opinions of experts and 

practitioners—that discussed best practices and policies for testing integrity.** 

Page 8 *See enclosure II for more information on leading practices by state.

**U.S. Department of Education, Institute of Education Sciences, National Center for Education Statistics, Testing Integrity Symposium: Issues and Recommendations for Best Practice (2013). 
Enclosure I: Briefing Slides

Page 13 GAO-13-495R Test Security Leading Practices

Background

• Since 2002, Education provided over $2 billion for state testing required under the 

Elementary and Secondary Education Act of 1965 (ESEA), as amended. ESEA 

requires states receiving ESEA, Part A funds to:

• develop high-quality academic assessments that measure students’ knowledge of 

reading/language arts, mathematics, and science; 

• test all students in grades 3 through 8 annually in mathematics and 

reading/language arts and at least once in grades 10 through 12; and 

• test students in science at least once during grades 3 through 5, 6 through 9, and 

10 through 12. 

• These assessments can be delivered via traditional pencil and paper or computerbased methods.

Page 9
Enclosure I: Briefing Slides

Page 14 GAO-13-495R Test Security Leading Practices

Background (cont.)

• Student performance, as measured in part by these assessments, is the basis for 

school accountability, including corrective actions such as removing principals, 

implementing new curricula, or restructuring schools. 

• Further, valid assessment results are necessary for resources to be accurately 

targeted to underperforming schools. For example, the School Improvement Grants 

program targets resources to schools that are below a certain threshold of student 

academic performance.

Page 10
Enclosure I: Briefing Slides

Page 15 GAO-13-495R Test Security Leading Practices

Background (cont.)

• Some states provide awards or recognition for improving assessment scores, which 

could provide incentives to cheat.

• According to our nationwide survey:

• 24 states* reported either providing awards or special recognition based on 

student test scores, 

• 24 states reported linking assessment scores to educator evaluations, and 

• 9 states reported linking assessment scores to promotions.

*Throughout this report, we refer to the District of Columbia as a state. Page 11
Enclosure I: Briefing Slides

Page 16 GAO-13-495R Test Security Leading Practices

Background (cont.)

• In 2010, the Council of Chief State School Officers (CCSSO) and the Association of 

Test Publishers (ATP) published a set of voluntary best practices in test security for 

states and testing companies.

• The practices were developed by a working group comprised of state education 

officials and representatives of test publishing companies and a test security firm.

• They cover topics central to designing, developing, administering, and scoring state 

assessments. 

Page 12
Enclosure I: Briefing Slides

Page 17 GAO-13-495R Test Security Leading Practices

Background (cont.)

• The working group reported applying several criteria to help ensure the practices 

they recommended were proven and would benefit users.

• For example, the working group assessed whether the practices were:

• used by more than one state or testing company;

• ready and available to be implemented; and 

• presented in a way that would permit alternative methods of attaining the 

same goal.

• CCSSO and ATP plan to publish a new guide that focuses on leading practices in 

test security for computer-based statewide assessments.

• According to the CCSSO and ATP document, states do not necessarily need to 

include all of the leading practices to have a successful test security program. 

Page 13
Enclosure I: Briefing Slides

Page 18 GAO-13-495R Test Security Leading Practices

Background (cont.)

• Education has led two initiatives aimed at collecting and sharing information on 

practices and policies that have been used to prevent, detect, and respond to testing 

irregularities:

• First, Education published a request for information in the Federal Register on 

January 17, 2012, asking the public to submit best practices and policies 

regarding prevention, detection, and investigation of testing irregularities.*

• In addition, on February 28, 2012, Education’s National Center for Education 

Statistics sponsored a symposium on testing integrity comprised of external 

experts and industry leaders to discuss best practices and how these practices 

might change for computer-based assessments.

*77 Fed. Reg. 2280 (Jan. 17, 2012). Page 14
Enclosure I: Briefing Slides

Page 19 GAO-13-495R Test Security Leading Practices

Page 15

Finding 1: Leading Practices

Extent of leading practices included in test security policies and procedures varied

According to our survey results, all states’ policies and procedures included many of the 

leading practices to prevent testing irregularities; however, they varied in the extent to 

which they incorporated these practices. Further, despite their established test security 

policies and procedures to prevent cheating, states reported being vulnerable to cheating 

at some point during the testing process. See enclosure II for a complete listing of the 

leading practices in each category and information on cases of leading practices reported 

by states.
Enclosure I: Briefing Slides

Page 20 GAO-13-495R Test Security Leading Practices

Finding 1: Leading Practices

Extent of leading practices included in test security policies and procedures varied

• All states reported having at least 50 percent (37 of 74) of the leading 

practices across five of the six categories: security plans; security training; 

security breaches; test administration; and protecting secure materials.*

Page 16

Source: GAO survey of state testing directors.

Figure 1: Number of states that reported having various percentages of leading practices 

across five categories of leading practices

50%

(37)

Percentage of 

leading practices

(Total = 74)

Number

of states 1 15 21 14

51% to 74%

(41-55)

75% to 89%

(56-66)

90% or more

(67-72)

*We also surveyed states to determine the extent to which they incorporated leading practices in computer-based testing. According to our survey, 28 states reported administering computer-based tests. 

Therefore, we report the results of that category separately later in this report. 
Enclosure I: Briefing Slides

Page 21 GAO-13-495R Test Security Leading Practices

• Leading practices for test 

security plans include having 

procedures for keeping 

testing facilities and 

materials secure, and 

methods of transferring hard 

copies of testing materials.

• Fourteen states reported 

having all (9 of 9) of the 

leading practices in this 

category.

• Additionally, within this 

category all 51 states 

reported having 

requirements for the security 

of testing materials.

Source: GAO survey of state testing directors. Page 17

Figure 2: Number of states that reported having various 

numbers of leading practices within the security plans category

Finding 1: Leading Practices – Test Security Plans

Extent of leading practices included in test security policies and procedures varied

Number of states

Number

of leading

practices

(Total = 9)

3

8

8

18

14

0 5 10 15 20

5

6

7

8

9
Enclosure I: Briefing Slides

Page 22 GAO-13-495R Test Security Leading Practices

• Security training leading 

practices include the 

development of training 

materials and conducting 

training on test security. 

• Twenty-two states reported 

having all (11 of 11) of the 

leading practices in this 

category.

• However, four states 

reported not having any of 

the leading practices in the 

security training category.

Source: GAO survey of state testing directors. Page 18

Figure 3: Number of states that reported having various numbers 

of leading practices within the security training category

Finding 1: Leading Practices – Security Training

Extent of leading practices included in test security policies and procedures varied

4

4

11

10

22

0 5 10 15 20 25

None

6 or 7

8 or 9

10

11

Number of states

Number

of leading

practices

(Total = 11)
Enclosure I: Briefing Slides

Page 23 GAO-13-495R Test Security Leading Practices

• Leading practices for dealing 

with security breaches include 

procedures to prevent potential 

breaches—such as coaching 

or altering test responses—

and steps to take if they occur, 

including consequences for 

individuals responsible for the 

breach.

• Twenty-four states reported 

having all (6 of 6) of the 

leading practices in this 

category.

• Three states reported not 

having any of the leading 

practices in the security 

breaches category. 

Source: GAO survey of state testing directors. Page 19

Figure 4: Number of states that reported having various numbers 

of leading practices within the security breaches category

Finding 1: Leading Practices – Security Breaches

Extent of leading practices included in test security policies and procedures varied

3

2

4

18

24

0 5 10 15 20 25

None

1 to 3

4

5

6

Number of states

Number

of leading

practices

(Total = 6)
Enclosure I: Briefing Slides

Page 24 GAO-13-495R Test Security Leading Practices

• Leading practices in test 

administration include procedures 

for securing

the testing environment

and preventing or managing 

possible testing irregularities, 

among other things. 

• Most states reported having over 

half of the 32 leading practices in 

this category. 

• However, within this category, 

only eight states reported having 

requirements for recording 

seating chart information, and 

only six states reported having 

requirements that teachers not 

proctor their own classrooms 

during statewide tests.

Page 20

Figure 5: Number of states that reported having various numbers 

of leading practices within the test administration category

Source: GAO survey of state testing directors.

Finding 1: Leading Practices – Test Administration

Extent of leading practices included in test security policies and procedures varied

4

2

24

21

0 5 10 15 20 25 30

6 to 10

18 to 20

24 to 28

29 to 31

Number of states

Number of leading

practices (Total = 32)
Enclosure I: Briefing Slides

Page 25 GAO-13-495R Test Security Leading Practices

• Leading practices for 

protecting secure materials 

include procedures to account 

for and protect secure 

materials at all

stages of distribution, receipt, 

storage and return.

• Seven states reported having 

all (16 of 16) of the leading 

practices in this category.

• However, fewer than half of the 

states reported having 

procedures for physical access 

controls (20 states) and visitor 

policy regulations (25 states). 

Source: GAO survey of state testing directors. Page 21

Figure 6: Number of states that reported having various numbers

of leading practices within the protecting secure materials category 

Finding 1: Leading Practices – Protecting Secure Materials

Extent of leading practices included in test security policies and procedures varied

7

14

23

7

0 5 10 15 20 25

3 to 8

9 to 12

13 to 15

16

Number of states

Number

of leading

practices

(Total = 16)
Enclosure I: Briefing Slides

Page 26 GAO-13-495R Test Security Leading Practices

• Computer-based practices 

include requirements that clearly 

document and explain the use of 

any software, including 

supporting devices such as 

scanners.

• Of the 28 states that reported 

administering computer-based 

tests, eight states reported 

having all (14 of 14) of the 

leading practices in this 

category; 19 of the remaining 20 

states reported having over half 

of the practices, with Kansas the 

only exception.

• By the 2014-15 school year, 47 

states are currently expected to 

be using computer-based 

assessments.*

Page 22

Figure 7: Number of states that reported having various numbers

of leading practices within the computer-based testing category 

Source: GAO survey of state testing directors.

*These states have entered partnerships to use computer-based tests to measure student progress against the Common Core State Standards, which provide a consistent understanding of what students 

are expected to learn. 

Finding 1: Leading Practices – Computer-based Testing

Extent of leading practices included in test security policies and procedures varied

5

8

7

8

0 5 10 15

5 to 9

10 to 12

13

14

Number of states

Number

of leading

practices

(Total = 14)
Enclosure I: Briefing Slides

Page 27 GAO-13-495R Test Security Leading Practices

45

43

47

50

40

0 5 10 15 20 25 30 35 40 45 50 55

Chain of custody

After test

During test

Before test

• Despite having a variety of policies and procedures to mitigate testing irregularities, many 

state officials reported feeling vulnerable to cheating at some point during the testing 

process.*

Source: GAO survey of state testing directors. Page 23 *This figure includes states responding that they felt “somewhat vulnerable”; “moderately vulnerable”; “very vulnerable”; or “extremely vulnerable” to cheating.

Figure 8: Number of states that reported being vulnerable during various stages of testing 

Finding 1: Leading Practices (cont.)

Regardless of security practices, states feel vulnerable to cheating

Number of states

When testing students in

need of accommodations
Enclosure I: Briefing Slides

Page 28 GAO-13-495R Test Security Leading Practices

Page 24

Finding 2: State Oversight

States used a variety of tools to oversee test security and identify cheating

States reported using several oversight tools to ensure that school districts are following 

test security policies and procedures. As a result of these oversight activities, 32 states 

reported voiding test scores because of suspected or confirmed instances of cheating 

by school officials in the past two school years.
Enclosure I: Briefing Slides

Page 29 GAO-13-495R Test Security Leading Practices

Page 25 Source: GAO survey of state testing directors.

Figure 9: Number of states (out of 51, including the District of Columbia) reporting that they used these 

tools to ensure that school districts and schools were following test security policies and procedures

Finding 2: State Oversight

States used a variety of tools to oversee test security and identify cheating

Analysis of

student data

Monitoring

visit

Remote

monitoring

Formal

audits

Outside

security firm

38 36

22 21

8

• State officials reported that they use a number of different oversight tools to 

ensure districts are following test security policies and procedures.

States using the 

oversight tools

States not using the 

oversight tools
Enclosure I: Briefing Slides

Page 30 GAO-13-495R Test Security Leading Practices

• State officials reported that, during the past two school years, they detected 

potential cheating as a result of the following state oversight activities.

Page 26

Finding 2: State Oversight (cont.)

States used a variety of tools to oversee test security and identify cheating

Note: Reporting mechanisms may include 

online or paper-based forms for reporting 

security breaches by district and school 

officials, parents, or students.

Figure 10: Number of states (out of 51, including the District of Columbia) reporting that they used these 

activities to detect reports of cheating in school years 2010-11 and 2011-12

Hotlines Reporting Monitoring Auditing

22 21 17 11

Source: GAO survey of state testing directors.

States using the activity to 

detect reports of cheating

States not using the activity to 

detect reports of cheating
Enclosure I: Briefing Slides

Page 31 GAO-13-495R Test Security Leading Practices

• Our analysis found that states also use statistical analysis of assessment data to 

identify suspicious patterns of scores at the classroom, grade, school, or district 

level that are highly unlikely and may suggest cheating.* 

• Officials from 37 states reported that they conducted formal statistical analyses to 

detect indications of cheating for the 2011-2012 testing cycle.

• For example, 33 states reported using erasure analysis, which usually 

focuses on the number or proportion of answers that were changed from 

wrong to right. 

• Twenty-eight states reported using gain or loss score analysis, which

considers whether average test score improvements are unusual relative to 

the average improvement in similar classrooms or grades.

Page 27 *These methods alone cannot verify whether cheating occurred. They can, however, inform future investigations or corroborate other reports of teachers or administrators 

cheating. 

Finding 2: State Oversight (cont.)

States used a variety of tools to oversee test security and identify cheating
Enclosure I: Briefing Slides

Page 32 GAO-13-495R Test Security Leading Practices

• State officials reported using the results of the statistical analyses 

to:

• inform training on assessment security (34 states),

• conduct investigations in schools (34 states),

• select districts or schools for monitoring visits (28 states), and

• make changes to state assessment security policies (26 states).

Page 28

Finding 2: State Oversight (cont.)

States used a variety of tools to oversee test security and identify cheating
Enclosure I: Briefing Slides

Page 33 GAO-13-495R Test Security Leading Practices

• Forty states reported allegations of cheating by school officials in the 

past two school years. Of these, 33 states confirmed at least one 

instance of cheating.* 

• Twenty-nine states reported allegations of cheating for school year 

2011-12, and a similar number reported allegations of cheating in 

school year 2010-11.

Page 29 *Allegations of cheating could include different numbers of individuals. For example, one allegation could cover one individual, multiple tests, grade levels, schools, or individuals.

Finding 2: State Oversight (cont.)

States used a variety of tools to oversee test security and identify cheating
Enclosure I: Briefing Slides

Page 34 GAO-13-495R Test Security Leading Practices

• In school years 2011-12 and 2010-11, 32 states reported canceling, invalidating, or 

nullifying test scores from individual students, schools, or districts because of 

suspected or confirmed cheating by school officials. 

• Some state and school district officials we interviewed during our site visits reported 

that test scores could be voided due to cheating; districts may face corrective actions; 

and educators may face personnel actions, such as removal of teaching credentials. 

Page 30

Finding 2: State Oversight (cont.)

States used a variety of tools to oversee test security and identify cheating
Enclosure I: Briefing Slides

Page 35 GAO-13-495R Test Security Leading Practices

Finding 3: States’ Sources of Assistance

States received assistance with test security, but seek additional support

Page 31

States relied on several sources of support for assistance with test security issues and 

identified additional areas where assistance from Education would be useful. Subsequent 

to our survey, Education issued a report that discusses best practices and policies for 

testing integrity. 
Enclosure I: Briefing Slides

Page 36 GAO-13-495R Test Security Leading Practices

Finding 3: States’ Sources of Assistance

States received assistance with test security, but seek additional support

Page 32 Source: GAO survey of state testing directors.

Figure 11: Primary sources of information states rely on for assistance with test security issues

• States reported receiving assistance with assessment security from several 

sources, but most frequently from testing contractors.
Enclosure I: Briefing Slides

Page 37 GAO-13-495R Test Security Leading Practices

• When asked in the survey—administered between November 2012 and January 

2013—how Education could best serve the states, officials from the majority of states 

reported that it would be very or extremely useful if Education would:

• gather information on best practices in test security (35 states), and

• disseminate information on best practices (36 states). 

• On February 12, 2013, Education released a report—consisting largely of the opinions 

of experts who responded to Education’s request for information or presented at the 

Testing Integrity Symposium—discussing practices and policies related to four areas of 

testing integrity. 

• Education stated that the document will be a starting point for further dialogue about 

the integrity of academic assessments. 

Page 33

Finding 3: States’ Sources of Assistance (cont.)

States received assistance with test security, but seek additional support
Enclosure I: Briefing Slides

Page 38 GAO-13-495R Test Security Leading Practices

• State officials reported other areas, which were not discussed in Education’s February 

2013 report, where additional assistance would be useful:

• Officials from 35 states said it would be very or extremely useful to have additional 

opportunities for state collaboration about assessment security issues.

• Additionally, about one-third of the states reported that it would be very or 

extremely useful if Education provided assistance with drafting requests for 

proposals for testing vendors. 

Page 34

Finding 3: States’ Sources of Assistance (cont.)

States received assistance with test security, but seek additional support
Enclosure I: Briefing Slides

Page 39 GAO-13-495R Test Security Leading Practices

Concluding Observations

As more information about leading practices in test security is developed and disseminated, 

states will have improved access to the tools they need to develop strong policies and 

procedures in test security, and reduce their vulnerability to cheating on assessments. In 

particular, as more states begin using computer-based assessments—which may address 

some vulnerabilities of paper-based assessments, but may also create new ones, such as 

computer security breaches—additional guidance and oversight will be key to ensuring that 

appropriate policies and procedures are adopted by schools to address these new 

vulnerabilities.

Although the risk of cheating on statewide assessments can never be completely 

eliminated, implementation of strong policies and procedures for preventing cheating, 

combined with robust oversight and detection by states, can greatly improve the integrity of 

test results. Without these measures, there is a higher risk that decisions based on test 

results may be faulty, and lead to damaging results, including failing to identify and provide 

resources for underperforming schools and students most in need of academic support.

Page 35
Enclosure II: Leading Practices Included in Policies and Procedures by Category Reported by Each State

Note: Cells marked with an “X” indicate that state officials responded “yes” to having the leading practice. Blank cells indicate that state officials did not respond, or responded “no” or “don’t know.” 

Page 40 GAO-13-495R Test Security Leading Practices

Table 1: Security Plans

Rules for 

Storage of 

Testing 

Materials

Security of 

Testing 

Materials

Internet 

Connectivity 

Procedures

Methods of 

Electronic 

Transfer

Methods of 

Transfer for 

Hard Copies of 

Testing 

Materials

Procedures for 

Removal of 

Materials After 

Testing is 

Complete

Procedures to 

Keep Testing 

Facilities 

Secure

Test Item 

Release 

Process Periodic Audits

AL X X X X X X X X 

AK X X X X X X 

AZ X X X X X X X X X

AR X X X X X X X X X 

CA X X X X X X X X

CO X X X X X X X X X 

CT X X X X X X X X 

DC X X X X X X X X X 

DE X X X X X X X X

FL X X X X X X X 

GA X X X X X X X X

HI X X X X X X 

ID X X X X X X X 

IL X X X X X X 

IN X X X X X X X X X 

IA X X X X X X X 

KS X X X X X X X X

KY X X X X X X X X X 

LA X X X X X X X X 

ME X X X X X X X X 

MD X X X X X X X X X

MA X X X X X X X 

MI X X X X X X

MN X X X X X X X X X 

MS X X X X X X X 

MO X X X X X X X X X 

MT X X X X X X X X
Enclosure II: Leading Practices Included in Policies and Procedures by Category Reported by Each State

Note: Cells marked with an “X” indicate that state officials responded “yes” to having the leading practice. Blank cells indicate that state officials did not respond, or responded “no” or “don’t know.” 

Page 41 GAO-13-495R Test Security Leading Practices

Rules for 

Storage of 

Testing 

Materials

Security of 

Testing 

Materials

Internet 

Connectivity 

Procedures

Methods of 

Electronic 

Transfer

Methods of 

Transfer for 

Hard Copies of 

Testing 

Materials

Procedures for 

Removal of 

Materials After 

Testing is 

Complete

Procedures to 

Keep Testing 

Facilities 

Secure

Test Item 

Release 

Process Periodic Audits

NE X X X X X X X X X 

NV X X X X X 

NH X X X X X X X 

NJ X X X X X X 

NM X X X X X X X X

NY X X X X X X 

NC X X X X X X X X X 

ND X X X X X X X X 

OH X X X X X

OK X X X X X X X X X 

OR X X X X X X X X

PA X X X X X X X X X 

RI X X X X X X X 

SC X X X X X X X X 

SD X X X X X X X

TN X X X X X X X X 

TX X X X X X X X X

UT X X X X X X X X 

VT X X X X X X X X 

VA X X X X X X X X X 

WA X X X X X X X X 

WV X X X X X X 

WI X X X X X X

WY X X X X X 

Source: GAO survey of state testing directors.
Enclosure II: Leading Practices Included in Policies and Procedures by Category Reported by Each State

Note: Cells marked with an “X” indicate that state officials responded “yes” to having the leading practice. Blank cells indicate that state officials did not respond, or responded “no” or “don’t know.” 

Page 42 GAO-13-495R Test Security Leading Practices

Table 2: Training

Key

1. Reporting Test Administration Irregularities and Security Breaches

2. Handling Allowable Accommodations

3. Ensuring Test Security During All Stages of Administration

4. Documentation how the Assessment is to be Administered 

5. Administering Test Under Normal Standardized Conditions

6. Dealing with Cases Involving Expected Collusion Between Adults

7. A Process for Addressing Unforeseen Difficulties with Test Administration

8. Answering Student Questions About the Assessment

9. Allowing Student Activities After Completing the Assessment if Students are Still 

Engaged in the Assessment

10. Standards for Triggering An Investigation

11. Protocols for Conducting An Investigation

1 2 3 4 5 6 7 8 9 10 11

AL X X X X X X X X X X X 

AK X X X X X X X X X X X 

AZ X X X X X X X X X X X 

AR X X X X X X X X 

CA X X X X X X X X X X X 

CO X X X X X X X X X X 

CT X X X X X X X X 

DC X X X X X X X X X X X 

DE X X X X X X X X X X 

FL X X X X X X X X X X X 

GA X X X X X X X X X X X 

HI X X X X X X X X X X 

ID X X X X X X X X X X 

IL X X X X X X X X X X 

IN X X X X X X X X X 

IA

KS X X X X X X 

KY X X X X X X X X X X X 

LA

ME X X X X X X X X X X X 

MD X X X X X X X X 
Enclosure II: Leading Practices Included in Policies and Procedures by Category Reported by Each State

Note: Cells marked with an “X” indicate that state officials responded “yes” to having the leading practice. Blank cells indicate that state officials did not respond, or responded “no” or “don’t know.” 

Page 43 GAO-13-495R Test Security Leading Practices

1. Reporting Test Administration Irregularities and Security Breaches

2. Handling Allowable Accommodations

3. Ensuring Test Security During All Stages of Administration

4. Documentation how the Assessment is to be Administered 

5. Administering Test Under Normal Standardized Conditions

6. Dealing with Cases Involving Expected Collusion Between Adults

7. A Process for Addressing Unforeseen Difficulties with Test Administration

8. Answering Student Questions About the Assessment

9. Allowing Student Activities After Completing the Assessment if Students are Still 

Engaged in the Assessment

10. Standards for Triggering An Investigation

11. Protocols for Conducting An Investigation

1 2 3 4 5 6 7 8 9 10 11

MA X X X X X X X X X X 

MI X X X X X X 

MN

MS X X X X X X X X X X X 

MO X X X X X X X X 

MT X X X X X X X X X

NE X X X X X X X X X X 

NV X X X X X X X X X X X 

NH X X X X X X X X X X 

NJ X X X X X X X X

NM X X X X X X X X X X X 

NY X X X X X X X X X X X

NC X X X X X X X X X X X 

ND X X X X X X 

OH

OK X X X X X X X X

OR X X X X X X X X X X X 

PA X X X X X X X X X X X

RI X X X X X X X X 

SC X X X X X X X X X X X 

SD X X X X X X X X X 

TN X X X X X X X X X X X 

TX X X X X X X X X X X X 

UT X X X X X X X X X X X

VT X X X X X X X X X X 

VA X X X X X X X X X X X 
Enclosure II: Leading Practices Included in Policies and Procedures by Category Reported by Each State

Note: Cells marked with an “X” indicate that state officials responded “yes” to having the leading practice. Blank cells indicate that state officials did not respond, or responded “no” or “don’t know.” 

Page 44 GAO-13-495R Test Security Leading Practices

1. Reporting Test Administration Irregularities and Security Breaches

2. Handling Allowable Accommodations

3. Ensuring Test Security During All Stages of Administration

4. Documentation how the Assessment is to be Administered 

5. Administering Test Under Normal Standardized Conditions

6. Dealing with Cases Involving Expected Collusion Between Adults

7. A Process for Addressing Unforeseen Difficulties with Test Administration

8. Answering Student Questions About the Assessment

9. Allowing Student Activities After Completing the Assessment if Students are Still 

Engaged in the Assessment

10. Standards for Triggering An Investigation

11. Protocols for Conducting An Investigation

1 2 3 4 5 6 7 8 9 10 11

WA X X X X X X X X X X 

WV X X X X X X X X X 

WI X X X X X X X X X X X 

WY X X X X X X X 

Source: GAO survey of state testing directors.
Enclosure II: Leading Practices Included in Policies and Procedures by Category Reported by Each State

Note: Cells marked with an “X” indicate that state officials responded “yes” to having the leading practice. Blank cells indicate that state officials did not respond, or responded “no” or “don’t know.” 

Page 45 GAO-13-495R Test Security Leading Practices

Table 3: Security Breaches

Procedures to Prevent 

Potential Security 

Breaches

A Recovery Plan for how 

to Mitigate a Security 

Breach

Information on Potential 

Consequences to 

Individual(s) 

Responsible for the 

Breach

Procedures to be 

Invoked if Security 

Breaches Occur that

Jeopardize Integrity of 

Student Test Score 

Results

Development of a Form 

for Documenting 

Breaches

A Communications Plan 

for All Stakeholders to 

Follow if a Breach 

Occurs

AL X X X X X X

AK X X X X X X 

AZ X X X X X 

AR X X X 

CA X X X X X X 

CO X X X X X 

CT X X X X X

DC X X X X X X 

DE X X X X X 

FL X X X X X X 

GA X X X X X X

HI X X X X X X 

ID X X X X X

IL X X X X 

IN X X X X X 

IA X X X X X 

KS X X X X X

KY X X X X X X 

LA X X X X X X

ME X X X X X 

MD X X X X X X 

MA X X X X X 

MI X X X X 

MN X X X X X 

MS X X X X

MO
Enclosure II: Leading Practices Included in Policies and Procedures by Category Reported by Each State

Note: Cells marked with an “X” indicate that state officials responded “yes” to having the leading practice. Blank cells indicate that state officials did not respond, or responded “no” or “don’t know.” 

Page 46 GAO-13-495R Test Security Leading Practices

Procedures to Prevent 

Potential Security 

Breaches

A Recovery Plan for how 

to Mitigate a Security 

Breach

Information on Potential 

Consequences to 

Individual(s) 

Responsible for the 

Breach

Procedures to be 

Invoked if Security 

Breaches Occur that

Jeopardize Integrity of 

Student Test Score 

Results

Development of a Form 

for Documenting 

Breaches

A Communications Plan 

for All Stakeholders to 

Follow if a Breach 

Occurs

MT X X X X X X

NE X X X X X X 

NV X X X X X X 

NH X 

NJ X X X X X X

NM X X X X X X 

NY X X X X

NC X X X X X X 

ND X X X X X 

OH X X X X X X 

OK X X X X X X 

OR X X X X X X 

PA X X X X X

RI X X X X X 

SC X X X X X X 

SD X X X X X 

TN X X X X X X

TX X X X X X X 

UT

VT X X X X X 

VA X X X X X X 

WA X X X X X X 

WV X X X X X

WI X X X X X 

WY

Source: GAO survey of state testing directors.
Enclosure II: Leading Practices Included in Policies and Procedures by Category Reported by Each State

Note: Cells marked with an “X” indicate that state officials responded “yes” to having the leading practice. Blank cells indicate that state officials did not respond, or responded “no” or “don’t know.” 

Page 47 GAO-13-495R Test Security Leading Practices

Table 4: Test Administration

Key

1. Procedures for Proper Handling of Secure Materials 

2. Procedures for Secure Storage of Materials Prior to Test Administration 

3. Procedures for Secure Storage of Materials During the Test

4. Procedures for Secure Storage of Materials After the Test

5. Procedures for Proper Handling of Tests Given with Accommodations and/or in Alternate 

Assessment Formats

6. Requirements to Obtain Confidentiality Agreements/Oaths from Proctors and/or 

Administrators

7. Rules and Procedures to Prevent/Respond to Instances of Test Administration 

Irregularities and/or Cheating

8. Requirements that Teachers Not Proctor their Own Classrooms for Statewide Tests

9. Identification of a Test Administrator to Student Ratio

10. Identification of Rooms for Administration and Their Requirements

11. Identification of Allowable and Expressly Prohibited Materials

12. Roles and Responsibilities for Assessment Proctors

13. An Overview of State Assessment Program, including laws and regulations

14. General Information About Particular Assessments

15. Ethical Practices

16. Regulations or Codes

17. Roles and Responsibilities of District and School Staff

18. Process for Determining Accommodations

19. Participation Requirements for Students in the Assessment Program

20. General Administration Guidance 

21. Provision of Accurate Student Information and Demographics

22. Reports Available Following Test Administration

23. Necessary Forms for the Assessment Program

24. Information on School Security Breaches or Test Irregularities

25. Procedures for Administration of Alternate Assessments 

26. Procedures for Ordering Additional Materials

27. Preparation of Testing Sites

28. Secure Distribution of Test Materials

29. Maintaining a Secure Inventory of Returned Test Materials

30. Procedures for Returning Test Materials to the Service Provider

31. Forms Used During Test Administration

32. Recording Seating Chart Information

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32

AL X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X 

AK X X X X X X X

AZ X X X X X X X X X X X X X X X X X X X X X X X X X X X X 

AR X X X X X X X X X X X X X X X X X X X X X X X X X X X X

CA X X X X X X X X X X X X X X X X X X X X X X X X X X X X X 

CO X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X 

CT X X X X X X X X X X X X X X X X X X X X X X X X X 

DC X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X 

DE X X X X X X X X X X X X X X X X X X X X X X X X 

FL X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X

GA X X X X X X X X X X X X X X X X X X X X X X X X X X X X X 

HI X X X X X X 
Enclosure II: Leading Practices Included in Policies and Procedures by Category Reported by Each State

Note: Cells marked with an “X” indicate that state officials responded “yes” to having the leading practice. Blank cells indicate that state officials did not respond, or responded “no” or “don’t know.” 

Page 48 GAO-13-495R Test Security Leading Practices

1. Procedures for Proper Handling of Secure Materials 

2. Procedures for Secure Storage of Materials Prior to Test Administration 

3. Procedures for Secure Storage of Materials During the Test

4. Procedures for Secure Storage of Materials After the Test

5. Procedures for Proper Handling of Tests Given with Accommodations and/or in Alternate 

Assessment Formats

6. Requirements to Obtain Confidentiality Agreements/Oaths from Proctors and/or 

Administrators

7. Rules and Procedures to Prevent/Respond to Instances of Test Administration 

Irregularities and/or Cheating

8. Requirements that Teachers Not Proctor their Own Classrooms for Statewide Tests

9. Identification of a Test Administrator to Student Ratio

10. Identification of Rooms for Administration and Their Requirements

11. Identification of Allowable and Expressly Prohibited Materials

12. Roles and Responsibilities for Assessment Proctors

13. An Overview of State Assessment Program, including laws and regulations

14. General Information About Particular Assessments

15. Ethical Practices

16. Regulations or Codes

17. Roles and Responsibilities of District and School Staff

18. Process for Determining Accommodations

19. Participation Requirements for Students in the Assessment Program

20. General Administration Guidance 

21. Provision of Accurate Student Information and Demographics

22. Reports Available Following Test Administration

23. Necessary Forms for the Assessment Program

24. Information on School Security Breaches or Test Irregularities

25. Procedures for Administration of Alternate Assessments 

26. Procedures for Ordering Additional Materials

27. Preparation of Testing Sites

28. Secure Distribution of Test Materials

29. Maintaining a Secure Inventory of Returned Test Materials

30. Procedures for Returning Test Materials to the Service Provider

31. Forms Used During Test Administration

32. Recording Seating Chart Information

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32

ID X X X X X X X X X X X X X X X X X X X X X X X X X X X X X 

IL X X X X X X X X X X X X X X X X X X X X X X X X X 

IN X X X X X X X X X X X X X X X X X X X X X X X X X X 

IA X X X X X X X X X X X X X X X X X X X X X X X X X X X X

KS X X X X X X X X X X X X X X X X X X X X X X X X X X X 

KY X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X

LA X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X 

ME X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X 

MD X X X X X X X X X X X X X X X X X X X X X X X X X X X X X 

MA X X X X X X X X X X X X X X X X X X X X X X X X X X 

MI X X X X X X X X X X X X X X X X X X X X X X X X X X 

MN X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X

MS X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X 

MO X X X X X X X X X X X X X X X X X X X X X X X X 

MT X X X X X X X X X X X X X X X X X X 

NE X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X
Enclosure II: Leading Practices Included in Policies and Procedures by Category Reported by Each State

Note: Cells marked with an “X” indicate that state officials responded “yes” to having the leading practice. Blank cells indicate that state officials did not respond, or responded “no” or “don’t know.” 

Page 49 GAO-13-495R Test Security Leading Practices

1. Procedures for Proper Handling of Secure Materials 

2. Procedures for Secure Storage of Materials Prior to Test Administration 

3. Procedures for Secure Storage of Materials During the Test

4. Procedures for Secure Storage of Materials After the Test

5. Procedures for Proper Handling of Tests Given with Accommodations and/or in Alternate 

Assessment Formats

6. Requirements to Obtain Confidentiality Agreements/Oaths from Proctors and/or 

Administrators

7. Rules and Procedures to Prevent/Respond to Instances of Test Administration 

Irregularities and/or Cheating

8. Requirements that Teachers Not Proctor their Own Classrooms for Statewide Tests

9. Identification of a Test Administrator to Student Ratio

10. Identification of Rooms for Administration and Their Requirements

11. Identification of Allowable and Expressly Prohibited Materials

12. Roles and Responsibilities for Assessment Proctors

13. An Overview of State Assessment Program, including laws and regulations

14. General Information About Particular Assessments

15. Ethical Practices

16. Regulations or Codes

17. Roles and Responsibilities of District and School Staff

18. Process for Determining Accommodations

19. Participation Requirements for Students in the Assessment Program

20. General Administration Guidance 

21. Provision of Accurate Student Information and Demographics

22. Reports Available Following Test Administration

23. Necessary Forms for the Assessment Program

24. Information on School Security Breaches or Test Irregularities

25. Procedures for Administration of Alternate Assessments 

26. Procedures for Ordering Additional Materials

27. Preparation of Testing Sites

28. Secure Distribution of Test Materials

29. Maintaining a Secure Inventory of Returned Test Materials

30. Procedures for Returning Test Materials to the Service Provider

31. Forms Used During Test Administration

32. Recording Seating Chart Information

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32

NV X X X X X X X X X X X X X X X X X X X X X X X X X X X 

NH X X X X X X X X X X X X X X X X X X X X X X X X X 

NJ X X X X X X X X 

NM X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X

NY X X X X X X X X X X X X X X X X X X X X X X X X X X X X X 

NC X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X

ND X X X X X X X X X X X X X X X X X X X X X X X X X X X X X 

OH X X X X X X X X X X X X X X X X X X X X X X X X X X X X 

OK X X X X X X X X X X X X X X X X X X X X X X X X X X X X X 

OR X X X X X X X X X X X X X X X X X X X X X X X X X X X X 

PA X X X X X X X X X X X X X X X X X X X X X X X X X X 

RI X X X X X X X X X X X X X X X X X X X X

SC X X X X X X X X X X X X X X X X X X X X X X X X X X X 

SD X X X X X X X X X X 

TN X X X X X X X X X X X X X X X X X X X X X X X X X X X 

TX X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X
Enclosure II: Leading Practices Included in Policies and Procedures by Category Reported by Each State

Note: Cells marked with an “X” indicate that state officials responded “yes” to having the leading practice. Blank cells indicate that state officials did not respond, or responded “no” or “don’t know.” 

Page 50 GAO-13-495R Test Security Leading Practices

1. Procedures for Proper Handling of Secure Materials 

2. Procedures for Secure Storage of Materials Prior to Test Administration 

3. Procedures for Secure Storage of Materials During the Test

4. Procedures for Secure Storage of Materials After the Test

5. Procedures for Proper Handling of Tests Given with Accommodations and/or in Alternate 

Assessment Formats

6. Requirements to Obtain Confidentiality Agreements/Oaths from Proctors and/or 

Administrators

7. Rules and Procedures to Prevent/Respond to Instances of Test Administration 

Irregularities and/or Cheating

8. Requirements that Teachers Not Proctor their Own Classrooms for Statewide Tests

9. Identification of a Test Administrator to Student Ratio

10. Identification of Rooms for Administration and Their Requirements

11. Identification of Allowable and Expressly Prohibited Materials

12. Roles and Responsibilities for Assessment Proctors

13. An Overview of State Assessment Program, including laws and regulations

14. General Information About Particular Assessments

15. Ethical Practices

16. Regulations or Codes

17. Roles and Responsibilities of District and School Staff

18. Process for Determining Accommodations

19. Participation Requirements for Students in the Assessment Program

20. General Administration Guidance 

21. Provision of Accurate Student Information and Demographics

22. Reports Available Following Test Administration

23. Necessary Forms for the Assessment Program

24. Information on School Security Breaches or Test Irregularities

25. Procedures for Administration of Alternate Assessments 

26. Procedures for Ordering Additional Materials

27. Preparation of Testing Sites

28. Secure Distribution of Test Materials

29. Maintaining a Secure Inventory of Returned Test Materials

30. Procedures for Returning Test Materials to the Service Provider

31. Forms Used During Test Administration

32. Recording Seating Chart Information

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32

UT X X X X X X X X X X X X X X X X X X X X X X X X X X X 

VT X X X X X X X X X X X X X X X X X X X X X X X X X X X X 

VA X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X 

WA X X X X X X X X X X X X X X X X X X X X X X X X X X X X

WV X X X X X X X X X X X X X X X X X X X X X X X X X X X X 

WI X X X X X X X X X X X X X X X X X X X X X X X X X X

WY X X X X X X X X X X X X X X X X X X X X X X X X X 

Source: GAO survey of state testing directors.
Enclosure II: Leading Practices Included in Policies and Procedures by Category Reported by Each State

Note: Cells marked with an “X” indicate that state officials responded “yes” to having the leading practice. Blank cells indicate that state officials did not respond, or responded “no” or “don’t know.” 

Page 51 GAO-13-495R Test Security Leading Practices

Table 5: Protecting Secure Materials

Key

Procedures to Keep Facilities Secure Chain of Custody Procedures 

1. Procedures on how Security Issues should be Managed at 

State and Local Levels 

2. Chain of Custody Procedures for Tracking all Secure Test 

Materials

3. Established and Documented Destination for Distribution

4. Plan to Account for and Return all Secure Materials

5. Plan for Secure Material's Disposition and Salvage

6. Procedures Describing What to Do when Test Materials are 

Missing

7. Physical Access Controls 

8. Visitor Policy Regulations

9. Security System for Online Security

10. Procedures for Online Security

11. Procedures for the Handoff of Materials

12. Process to Request Additional Materials

13. Procedures Describing What to Do when Materials are 

Missing

14. Instructions on Reassembling Scorable and Secure 

Materials

15. Instructions on Shipping Materials to the Service Provider

16. Procedures for Recovering Materials Provided by the 

Client and Service Provider

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16

AL X X X X X X X X X X X X X X

AK X X X X X X X X X X X 

AZ X X X X X X X X X X X X X

AR X X X X X X X X X X X X X X 

CA X X X X X X X X X X 

CO X X X X X X X X X X X 

CT X X X X X X X 

DC X X X X X X X X X X X X X X 

DE X X X X X X X X X X X X

FL X X X X X X X X X X X X X 

GA X X X X X X X X X X X X X X X X 

HI X X X X X X X X X 

ID X X X X X X X X X X X X X X

IL X X X X 

IN X X X X X X X X X X X X X X

IA X X X X X X X X X X X X X X 

KS X X X 

KY X X X X X X X X X X X X X X X 

LA X X X X X X X X X

ME X X X X X X X X X X X X X X X 
Enclosure II: Leading Practices Included in Policies and Procedures by Category Reported by Each State

Note: Cells marked with an “X” indicate that state officials responded “yes” to having the leading practice. Blank cells indicate that state officials did not respond, or responded “no” or “don’t know.” 

Page 52 GAO-13-495R Test Security Leading Practices

Procedures to Keep Facilities Secure Chain of Custody Procedures 

1. Procedures on how Security Issues should be Managed at 

State and Local Levels 

2. Chain of Custody Procedures for Tracking all Secure Test 

Materials

3. Established and Documented Destination for Distribution

4. Plan to Account for and Return all Secure Materials

5. Plan for Secure Material's Disposition and Salvage

6. Procedures Describing What to Do when Test Materials are 

Missing

7. Physical Access Controls 

8. Visitor Policy Regulations

9. Security System for Online Security

10. Procedures for Online Security

11. Procedures for the Handoff of Materials

12. Process to Request Additional Materials

13. Procedures Describing What to Do when Materials are 

Missing

14. Instructions on Reassembling Scorable and Secure 

Materials

15. Instructions on Shipping Materials to the Service Provider

16. Procedures for Recovering Materials Provided by the 

Client and Service Provider

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16

MD X X X X X X X X X X X X X X X X 

MA X X X X X X X X X X X X X 

MI X X X X X X X X X X X X X X

MN X X X X X X X X X X X X X X 

MS X X X X X X X X X X X X X X

MO X X X X X X X X X X X X X X 

MT X X X X X X X X 

NE X X X X X X X X X X X X X X X 

NV X X X X X X X X X X X X X X 

NH X X X X X 

NJ X X X X X X X X X X X X X

NM X X X X X X X X X X X X X 

NY X X X X X X X X X X X X 

NC X X X X X X X X X X X X X X X X 

ND X X X X X X X X X X X X X X X X

OH X X X X X X X X X X X X 

OK X X X X X X X X X X X X X X X X

OR X X X X X X X X X X X X X X 

PA X X X X X X X X X X X X X 

RI X X X X X X X X X X 

SC X X X X X X X X X

SD X X X X X X X X X X 

TN X X X X X X X X X X X X
Enclosure II: Leading Practices Included in Policies and Procedures by Category Reported by Each State

Note: Cells marked with an “X” indicate that state officials responded “yes” to having the leading practice. Blank cells indicate that state officials did not respond, or responded “no” or “don’t know.” 

Page 53 GAO-13-495R Test Security Leading Practices

Procedures to Keep Facilities Secure Chain of Custody Procedures 

1. Procedures on how Security Issues should be Managed at 

State and Local Levels 

2. Chain of Custody Procedures for Tracking all Secure Test 

Materials

3. Established and Documented Destination for Distribution

4. Plan to Account for and Return all Secure Materials

5. Plan for Secure Material's Disposition and Salvage

6. Procedures Describing What to Do when Test Materials are 

Missing

7. Physical Access Controls 

8. Visitor Policy Regulations

9. Security System for Online Security

10. Procedures for Online Security

11. Procedures for the Handoff of Materials

12. Process to Request Additional Materials

13. Procedures Describing What to Do when Materials are 

Missing

14. Instructions on Reassembling Scorable and Secure 

Materials

15. Instructions on Shipping Materials to the Service Provider

16. Procedures for Recovering Materials Provided by the 

Client and Service Provider

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16

TX X X X X X X X X X X X X X X X X 

UT X X X X X X X X X X X X X 

VT X X X X X X X X X X X X X X X

VA X X X X X X X X X X X X X X X X 

WA X X X X X X X X X X X X

WV X X X X X X X X X X X X 

WI X X X X 

WY X X X X X 

Source: GAO survey of state testing directors.
Enclosure II: Leading Practices Included in Policies and Procedures by Category Reported by Each State

Note: Cells marked with an “X” indicate that state officials responded “yes” to having the leading practice. Blank cells indicate that state officials did not respond, or responded “no” or “don’t know.”

Page 54 GAO-13-495R Test Security Leading Practices

Table 6: Computer-Based

Key

Protocols

Secure electronic 

transfer Requirements

Maintaining Security of online 

environment Training

1. Limited Internet Access

2. Logs to Monitor Access

3. Checking for Other Devices

4. Identity Checks/Seating Charts

5. Encrypted Data 

Exchange

6. Secure FTP Sites

7. Use of Software

8. Minimum Technology 

Infrastructure

9. Infrastructure Readiness

10. Security of Online Environment

11. Locking Down Computer

12. Securing Cell Phones and Other

Devices

13. Establish Security Codes

14. Specific Written 

Training 

Procedures

1 2 3 4 5 6 7 8 9 10 11 12 13 14

AR X X X X X X X X X X X X X 

CT X X X X X X X X 

DE X X X X X X X X X X X X X 

FL X X X X X X X X X X X X X X 

GA X X X X X X X X X X X X X X 

HI X X X X X X X X X X X X 

ID X X X X X X X X X 

IN X X X X X X X X X X 

KS X X X X X 

KY X X X X X X X X X 

LA X X X X X X X X X X X 

MD X X X X X X X X X X X X X X 

MN X X X X X X X X X X X X 

MS X X X X X X X X X X X X X 

MO X X X X X X X X X X 

NE X X X X X X X X X X X X X X 

NC X X X X X X X X X X X X X 

ND X X X X X X X X X X 

OK X X X X X X X X X X X X X X 

OR X X X X X X X X X X X X 

PA X X X X X X X X X X X X 

SC X X X X X X X X X X X X X X 
Enclosure II: Leading Practices Included in Policies and Procedures by Category Reported by Each State

Note: Cells marked with an “X” indicate that state officials responded “yes” to having the leading practice. Blank cells indicate that state officials did not respond, or responded “no” or “don’t know.”

Page 55 GAO-13-495R Test Security Leading Practices

Protocols

Secure electronic 

transfer Requirements

Maintaining Security of online 

environment Training

1. Limited Internet Access

2. Logs to Monitor Access

3. Checking for Other Devices

4. Identity Checks/Seating Charts

5. Encrypted Data 

Exchange

6. Secure FTP Sites

7. Use of Software

8. Minimum Technology 

Infrastructure

9. Infrastructure Readiness

10. Security of Online Environment

11. Locking Down Computer

12. Securing Cell Phones and Other

Devices

13. Establish Security Codes

14. Specific Written 

Training 

Procedures

1 2 3 4 5 6 7 8 9 10 11 12 13 14

TX X X X X X X X X X X X X X X 

UT X X X X X X X X X X X X X 

VT X X X X X X X X X 

VA X X X X X X X X X X X X X 

WA X X X X X X X X X X X X X 

WV X X X X X X X X X X X X X X 

Source: GAO survey of state testing directors.

Note: Officials from the 28 states listed in this table reported administering computer-based statewide assessments. Therefore, we only report the responses of those 28 states for 

the computer-based category of leading practices.
Enclosure III: Comments from the U.S. Department of Education

Page 56 GAO-13-495R Test Security Leading Practices

(131159)
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