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Exhibit Number 9

Procedures for Testing Irregularities and Compromises


Testing irregularities and compromises pose a threat to the integrity of the GED® testing program. A major responsibility of all GED Chief Examiners™ and GED Examiners™ is to take all necessary precautions to minimize the possibility that an irregularity or compromise will occur at their GED® testing center. Strictly following GED Testing Service policies and procedures is the best way to prevent the occurrence of irregularities and compromises or to minimize the effect if a problem occurs.


Testing irregularities are any significant occurrence that generally disrupts a GED test candidate’s (“Candidate’s”) ability to focus on testing. Such an occurrence could result in an invalid measure of the Candidate’s performance. Although many irregularities are out of the direct control of the examiners, administering the tests in strict accordance with GED Testing Service policies and procedures can minimize their occurrence and impact. Testing irregularities must be reported to the jurisdictional GED Administrator™ and GED Testing Service as soon as possible. It is important to review whether an irregularity was avoidable or unavoidable and to evaluate the examiner’s management of the situation.


a. All GED® candidates are entitled to a quiet, comfortable testing environment that is as free as possible from distractions. The GED Chief Examiner™ or GED Examiner™ is responsible for preserving the quality of the testing environment. GED® candidates should be advised of this policy before testing begins. When one candidate’s activity or behavior disrupts the fair-testing environment, it is the prerogative of the GED Chief Examiner™ or GED Examiner™ to speak to the candidate at fault. The candidate should be informed that continued disruption will result in the following:

      • The candidate’s dismissal from the testing room.
      • The invalidation of the Candidate’s test scores.
      • The potential suspension of the Candidate’s future testing privileges.

b. Examiners should attempt to intervene early to protect the other candidates and prevent the disruption from resulting in a more serious test compromise situation.


Events beyond the control of the examiner may occur, such as a fire alarm going off, unexpected evacuation orders due to weather, power outages, etc. In these circumstances, the examiner must make every effort to secure testing materials to avoid any compromise. Depending on the nature of the event, the examiner may need to cancel the testing session or may resume testing. In any case, the examiner should document the testing irregularity and describe how the situation was managed. This information should be forwarded to the jurisdictional GED Administrator™ for review.


a. A test compromise occurs whenever:

      1. A whole or partial test battery is lost or stolen (including any lost materials such as an used answer sheet).
      2. Any unauthorized person has access to the GED® tests.
      3. A GED® candidate copies from another candidate.
      4. An individual impersonates a GED® candidate and attempts to take the test.
      5. Examiners or candidates share information about the GED® tests.
      6. GED® candidates receive answers to test questions in advance of the scheduled testing date.

b. Test loss or compromise is a serious threat to the integrity of the GED® testing program. Every effort must be made to prevent such compromises from occurring. In many cases, test loss or compromise occurs because of human error. Adherence to GED Testing Service policies related to how tests should be used, stored, transported, and accounted for will limit compromises.

c. The GED Administrator™ and GED Testing Service will determine the radius of the area affected, taking into account factors such as the nature of the compromise and the geographic nature of the region. The additional fees may also include the cost to replace any compromised GED® test content, in whole or in part.

d. Unauthorized exposure can result from noncompliance with any test storage, administration, or other procedures described in this manual, such as, but not limited to:

      1. Allowing the advance disclosure of any item on the GED® tests to a GED® candidate or potential candidate.
      2. Disclosing an essay topic to a GED® instructor or GED® candidate.
      3. Giving a GED® candidate access to a test booklet when investigating a challenge of scores.
      4. Indicating a GED® candidate’s raw score(s) to anyone.
      5. Permitting GED® tests, used answer sheets, or questions to be copied, photographed, or otherwise memorized in any format.
      6. Permitting access to the GED® tests, even if by negligence, to anyone other than approved GED Chief Examiners™ or GED Examiners™.
      7. Permitting used scratch paper, essay drafts, and similar items to remain in the custody of GED® candidates or storing such items in an unsecured manner prior to destroying them.
      8. Allowing anyone other than the GED Chief Examiner™, GED Examiner(s) ™, GED Proctors™, GED candidates™, the state administrator, or a representative of the GED Testing Service to enter the testing room.
      9. Describing to a GED® candidate the items that the candidate did not answer correctly.

e. Whenever possible, in staff meetings and daily contacts, the GED Chief Examiner™ and GED Examiners™ should emphasize to GED® instructors that post-test “debriefing” of a GED® candidate is not only a violation of that candidate’s privacy, but also a violation of test security that could result in the permanent closure of the GED® testing center.


When the GED Chief Examiner™ or GED Examiner™ suspects that a GED® candidate is copying another candidate’s paper, using unauthorized aids, impersonating another individual (i.e., “surrogate testing”), using false identification, has had prior access to the GED® tests or to essay anchor/recalibration papers, or has engaged in other improper conduct, the Chief Examiner or GED Examiner must promptly do the following:

      1. Minimize the disruption to other candidates.
      2. Remove the individual(s) in question from the testing room, only if doing so does not disrupt the testing session or present a physical threat to the GED Chief Examiner™ or GED Examiner™ or to another candidate.
      3. In the examiner’s discretion, permit the individual to complete the testing session, then invalidate the scores immediately and report the incident to the GED Administrator™ and GED Testing Service, which will decide what further action is appropriate.
      4. Inform the jurisdictional GED Administrator™, the institution that sponsors the official GED® testing center, and the GED Testing Service of the incident.
      5. Obtain statements from any candidates and/or staff members who observed the activity and attach these statements (ideally, signed by the candidate or staff member) to the written report.
      6. Prepare a written report recording specific details of the compromise.

GED Testing Service requires that a candidate’s scores be held and secured, for possible invalidation, when the GED Chief Examiner™ or GED Examiner™ observes candidate behavior that results in a compromise. The GED Chief Examiner™ or GED Examiner™ must delay reporting scores to any candidate who is suspected of compromised testing until an investigation has been completed.


If a test booklet, scored answer booklet, used answer sheet or any secure scoring material is misplaced, lost, or compromised in any way, the GED Chief Examiner™ or GED Examiner™ must adhere to the following procedures.

No request to resume testing will be considered until the official GED® testing center where the loss or compromise occurred has fulfilled all the requirements in the following list. When a compromise occurs, an official GED® testing center should expect to be closed.

  1. Upon discovery of loss or compromise of secure testing material, all administration of the GED® tests at the official GED® testing center must stop at once. No further testing may be conducted.
  2. If the GED Chief Examiner™ or GED Examiner™ concludes that secure testing materials have been lost or stolen, the loss or theft must be reported to the municipal or county police.
  3. The GED Chief Examiner™ or GED Examiner™ must immediately—within the hour or, if after 4:45 p.m. Eastern Standard Time (EST), at the opening of the following business day— report both by telephone and in writing by email to [email protected] any missing material(s), including test booklets, topic cards, scored answer sheets, or scratch paper, and must specify their form and serial numbers to the chief administrative officer (school district superintendent, college president or dean, or other institution official who signed the GED® annual contract), the GED Administrator, the GED Testing Service, and the official GED® testing center’s official scoring site.
  4. GED® test results or score reports from all GED® candidate(s) at any testing session in which a test loss or compromise occurred cannot be released until (a) the cause and extent of the loss can be determined, and (b) permission to release scores has been issued by the GED Administrator.
  5. Form L-24 should be completed by the examiner in charge of testing when the compromise occurred and submitted to the GED Administrator™ and GED Testing Service by email to [email protected] within two business days after the discovery of the compromise.
  6. The GED Chief Examiner™ or GED Examiner™ must begin an investigation immediately into the location of any missing material, the reason for the loss, and the extent of the loss.
  7. The investigation by the GED Chief Examiner™ or GED Examiner™ must include a detailed review of all test administration procedures and security measures observed at the official GED® testing center. Test compromises typically result from a combination of factors rather than from a single error. A complete self-evaluation by the official GED® testing center is the first step toward preventing future problems.
  8. If there is any conceivable threat to test security at any official GED® testing center within the region, the GED Administrator™ must be consulted for direction. If so directed by the GED Administrator™, the GED Chief Examiner™ or GED Examiner™ must immediately notify other official GED®testing centers to discontinue use of the compromised materials until further notice. The extent of the geographic area and the GED® testing centers affected by the test compromise will be determined by the GED Administrator™ and the GED Testing Service on the basis of geographic factors and the nature of the test compromise.
  9. If a compromised test form must be recalled from neighboring GED testing centers, the official GED® testing center at which the loss occurred may be required to assume the costs of restocking the neighboring testing centers with replacement testing materials at full leasing costs. This rule applies even if the radius of the affected area extends into another jurisdiction.
  10. If the investigation determines that a form of the GED® tests may have been compromised, the remaining stock of testing materials of that form must be returned to GED as directed.  Contact [email protected] for instructions.  The full cost of replacement will be charged for all impacted forms if and when a testing center is authorized to resume testing. Replacement costs may also be imposed for a compromised GED® test form or compromised test content.
  11. The GED Administrator™ should try to arrange access to testing for GED® Candidates who miss opportunities to take the GED® tests as a result of the test compromise. Testing may be arranged by the office of the GED Administrator™ or in a transportation addendum from a neighboring official GED testing center, as determined by the GED Administrator™. Materials and test administration staff of the official GED® testing center where the compromise took place may not be used in administering the tests. The GED Chief Examiner™ or GED Examiner™ of the testing center under investigation must support the effort by providing the information and resources needed to contact and reschedule the GED® Candidates who were impacted.
  12. The GED Administrator™ or an official representative must visit the official GED® testing center where the test compromise occurred and must consult with the GED Chief Examiner™ or GED Examiner(s) ™ concerning appropriate procedures. The results of the visit must be included in the final report of the GED Chief Examiner™ or GED Examiner™.
  13. A written report and written action plan must be submitted by the GED Chief Examiner™ to the official GED®testing center’s chief administrative officer, the GED Administrator™, and the GED Testing Service within seven business days. The final report and corrective action plan shall include a detailed description of the following::
        1. All circumstances that led to the loss or compromise.
        2. Testimony of any official GED Testing Center staff members or GED® candidates that has any bearing on the incident (ideally, signed by the individual providing the statement).
        3. Recommendations by the GED Administrator™.
        4. Security measures that will be initiated to prevent future compromise.
        5. Any administrative changes that will facilitate improved security measures.
        6. A copy of the local police report, if available.

No further testing may be conducted until the GED Administrator™ and GED Testing Service agree to the reopening of the center.

If GED Testing Service approves the recommendation to resume testing, the GED Administrator™ will be notified. The decision as to whether to permit testing to resume is a joint decision of the GED Administrator™ and GED Testing Service.


Any loss or compromise may result in (a) the permanent closure of an official GED® testing center, (b) GED Testing Service refusal to permit the current GED Chief Examiner™, GED Examiner™, or other testing center staff members future access to the GED® tests, and/or (c) the imposition of various costs on the applicable jurisdiction to compensate for the harm caused by the security breach.