what they are falsifying typically has to be actual quantitative test results, which is a much higher level of fraud than borderline accommodations

Makes sense.

The other place that is more likely to be fudging qualifications for accommodations is actually school guidance offices, since they are not required to submit evaluations in every case. College Board could audit them, and then they would have to come up with the testing, but rarely does, so they don't.

That's curious. I wonder why College Board wouldn't just institute a blanket requirement for testing and evaluations to be appended in all cases of accommodation, whether supplied by guidance offices or clinicians. Presumably there isn't a lot of marginal work for the guidance office if there is already a clinical eval, is that right? That kind of cursory box check (e.g. is an attachment uploaded? are certain keywords hit? are scores typed in auto-fill fields for the instrument(s) used?) could be audited with AI tech used for electronic medical records.

Say (I'm making this up) 25% of College Board users require an accommodation. For a share in that ballpark, it's just a question of adjusting the fee structure of the tests across the board to factor in the audit costs. Say it takes 1/4 - 1/2 of a clinical hour for a psychologist to adjudicate a case file at a fee of $200; the expected cost amortized across all tests is $12.50 to $25.00. I imagine you could even have full pass-through of the costs to university partners, who themselves would benefit from a more accurate candidate profile and save costs in their own evaluations from such a measure in that range.

ETA: Just checked College Board, and there were 2.2MM test takers in the US in 2019. The incremental fee would be $27.5MM - $55MM as above. I can only find data for 2017 on 4-year US colleges: there were ~2,800. If the top 10% covered the incremental costs, that's about $200K each of extra spend for audit quality with the higher figures, with 90% of colleges getting a free ride. If everyone chipped in equally, it's under $20K/year each. That's a drop in the bucket, when you consider potential legal fees and goodwill damage from admissions fraud. I'd take that bet.
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