Lowering Licensure Standards Puts Kentuckians’ Eye Health At Risk

[Gretchyn Bailey]

Released: May 27, 2025

The Kentucky Board of Optometric Examiners is seeking to lower the standards of the optometry profession and patient care in the commonwealth by proposing a regulatory amendment that would eliminate the requirement that applicants for an optometry license demonstrate baseline competence in the fundamentals of biomedical science. Instead, the proposed regulation would grant optometry licenses to applicants who never take or who have failed the National Board of Examiners inOptometry (NBEO®) Part I exam in applied basic science, allowing them to “substitute” a passing score on a foreign exam that does not test those content areas.

Last month, NBEO representatives, along with several others stakeholders, testified before the Kentucky General Assembly to advocate against a proposal to allow applicants for optometric licensure in Kentucky to avoid proof of successfully passing the NBEO Part I ABS® exam—which is required for an optometry license by every U.S. state—by presenting a passing score on the Optometry Examining Board of Canada (OEBC) online exam. The Administrative Regulation Review Subcommittee had already voted to push the amendment forward prior to hearing any testimony. The amendment is now being considered by the Interim Joint Committee on Health Services (as early as June). Unless the Interim Joint Committee disapproves the proposed amendment, it will become law.

If the proposed amendment is permitted to become law by the Interim Joint Committee on Health Services, Kentucky would be the only state in the country to accept the OEBC exam for optometric licensure. The OEBC exam is not equivalent to the NBEO exam because it does not test the foundational biomedical science principles necessary for safe and skilled patient care. This is because the OEBC examination is designed for the much more limited scope of optometric practice in Canada. Optometrists in Kentucky perform many medical functions that optometrists in Canada must refer to an ophthalmologist. A core understanding of anatomy, physiology, pharmacology, etc. is essential for appropriately treating and managing patients, especially as it pertains to the advanced procedures that optometrists in Kentucky are licensed to perform, including laser surgery, small excision surgery, injections, and certain prescription authority.

In addition, the NBEO exam—like other medical profession licensing exams in the U.S.—is administered in secure testing centers. By contrast, the OEBC written exam is administered remotely, which can present ethical and security risks. In fact, a recent study showed that remotely proctored candidates are up to 7 times more likely to be flagged for suspected collusion than in-person proctored candidates.

The NBEO three-part exam series has been rigorously developed by subject matter experts based on job task analyses for the practice of optometry in the U.S., and it has been psychometrically validated. Every state in the U.S. accepts passing scores on NBEO’s three-part sequence of exams on applied basic science (Part I) and patient assessment, diagnosis and treatment (Part II), and a performance exam with simulated live patient encounters (Part III) for initial licensure as a doctor of optometry. The content covered by the NBEO three-exam sequence aligns with the training that optometry students receive in accredited programs. Successful passage of the exam series assures both regulatory boards and the public that a candidate has the clinical knowledge, skills, and competencies needed to practice optometry upon entry to the profession.

The OEBC, however, has not been validated for Kentucky’s scope of practice. Accepting the OEBC as a “substitute” for the NBEO Part I exam would be inconsistent with professional standards and would raise serious questions about the psychometric and legal defensibility of the resulting licensure decisions. Indeed, NBEO believes that the proposed regulation fails to satisfy the statutory requirement in KRS 320.250 that the Kentucky Board issue licenses “only” to applicants who have passed examinations that “shall determine the applicant’s preparedness to exercise” the “skills needed for the practice of optometry in this Commonwealth at the time of the examination.”

The Kentucky Board’s stated justification of the purported “necessity” for the proposed amendment is that “[p]ost pandemic, there were a number of optometry school students that could not pass the National boards as required in current Kentucky regulation.” NBEO is aware that first-time pass rates on its exams dipped nationwide for optometry students whose preparation was negatively impacted by the forced pivot to remote learning during the pandemic. Pass rate data shows, however, that both first-time and ultimate pass rates are rising again. To the extent this was a problem, it was a temporary one that does not warrant a change that would put Kentucky dramatically out of step with the rest of the country. More significantly, lowering the standards for entry to the profession is not the right response to learning that a cohort of applicants lacked the needed preparation or skills to pass the licensure exams due to the impacts of the pandemic.

Although this proposed regulatory change has advanced largely under the radar, many ODs in Kentucky and other groups who have learned of the proposal have expressed alarm that Kentucky would lower its licensure standards. They agree that the high standards of the NBEO exam series are critical to protecting the public and to maintain confidence in the optometry profession in Kentucky. The Federation of Associations of Regulatory Boards (FARB), the National Association of VA Optometrists (NAVAO), and the Association of Regulatory Boards of Optometry (ARBO) have all submitted letters in opposition to the proposed amendment (see letters here).

NBEO believes in our mission to protect the public by developing, administering, scoring, and reporting results of valid examinations that assess competency in optometry. Because this proposal has been pushed forward without first gathering the input of stakeholders within optometry or performing any comparability or validation studies on the OEBC examination, we are actively working in Kentucky to oppose this regulatory amendment. If the proposed change goes into effect, patients who are harmed by licensed but unqualified optometrists in Kentucky would rightly be left to wonder why lawmakers failed to protect their health and safety. NBEO is committed to ensuring that lawmakers have the information they need to evaluate and reject this proposal to lower the standards for Kentucky optometrists.

For more information, a one pager overviewing the issue in Kentucky can be viewed here. You can also view letters both ARBO and NBEO have sent to the Kentucky General Assembly here. We welcome the opportunity to discuss this further if you have questions or want to support this effort. Please reach out to nbeo@optometry.org or 704-332-9565 directly.

Sincerely,
The National Board of Examiners in Optometry
Michael W. Ohlson, OD, President
James S. Campbell, OD, Vice President
Joshua Baker, MS, ODSecretary-Treasurer
Susy Yu, OD, MBA, Board Member
Patrick O’Neill, OD, Board Member
Daniel A. Taylor, OD, EdD, MS, MBA, Board Member
Gary Y. Chu, OD, MPH, Board Member
Caroline M. Kolman, PE, MBA, Board Member
Jill Bryant, OD, MPH, Executive Director

 

[Mike Alvarez]

Who is supporting this? Is this someone’s way of dealing with the below average pass rates at the Kentucky School?

 

[Steven E. Nelson]

This entire article is rife with bias.

If you read, it says they’re required to substitute “a foreign exam.” I read this much more as questioning the validity of NBEO than “basic science.”

This whole article feels like Ohlson’s strawman argument that if you’re criticizing NBEO or questioning its validity, you must be against standards in general.

If you think there aren’t plenty of folks looking at the absolute carnival of horror this year has been wondering if NBEO is even a valid metric anymore, you’re either crazy or named Farkas/Ohlson.

I know I certainly am and I’m the guy that almost got kicked off of a Facebook group for saying that if you can’t pass Boards, you shouldn’t even get a diploma.

What I’d like is someone from the KY board to explain their rationale before we just all jump on the propaganda bandwagon.

The biggest surprise to me is that the state boards or schools haven’t come up with an alternative themselves after all this.

 

[AdminWolf]

The biggest surprise to me is that the state boards or schools haven’t come up with an alternative themselves after all this.

You've just answered your own question - because the alternative would lead them precisely to where they already are right now ... Times 52.

Reinventing the wheel seldom works out the way people think it will.

 

[Jeffrey Kiener]

TLDR

 

[Steven E. Nelson]

TLDR

Basically, there’s a super biased article that suggests that because KY is looking at alternatives to NBEO (like the Canadian test), they’re against testing basic science.

It could be true or they could just be part of the growing population for whom the NBEO has lost all credibility.

I’d like someone in the know from KY to weigh in on this rather than what’s clearly a subscriber to the strawman “if you’re against how the NBEO has performed this year, you don’t care about standards.”

 

[Brian Spittle]

Basically, there’s a super biased article that suggests that because KY is looking at alternatives to NBEO (like the Canadian test), they’re against testing basic science.

It could be true or they could just be part of the growing population for whom the NBEO has lost all credibility.

I’d like someone in the know from KY to weigh in on this rather than what’s clearly a subscriber to the strawman “if you’re against how the NBEO has performed this year, you don’t care about standards.”

This couldn't possibly be a super biased response to a super biased article, could it?

 

[Mike Alvarez]

I’d like someone in the know from KY to weigh in on this rather than what’s clearly a subscriber to the strawman “if you’re against how the NBEO has performed this year, you don’t care about standards.”

100%.

 

[Michael W Ohlson]

TLDR

It is rather long.

While NBEO isn’t perfect, dropping/reducing the testing of biomedical sciences, accepting non-equivalent assessments, adding risks… bad reaction to temporary issues. This is particularly true with state legislative regulatory cmtes.

Test developers, such as NBEO and its individual staff members, have duties to speak out when assessments are not used as intended, information is incomplete, and so on. That’s the gist.

 

[Steve Silberberg]

If ODs want mobility of licensure this is certainly a step in the wrong direction

 

[Michael W Ohlson]

If ODs want mobility of licensure this is certainly a step in the wrong direction

You’ll likely find no positives. I understand the stakeholder upset regarding pass rates, fee increases, and the reporting error on a cohort.

However, the cut scores were not raised and the test difficulty was not increased. Unfortunately, the fee increase became necessary; NBEO has been quite straight-forward as to the reasons. We deeply regret the reporting error, took proper corrective measures, and made amends to those affected.

The above facts do not equate to accepting non-equivalent licensure assessments and negation of biomedical sciences in optometry. There are many reasons why such reactions are not good for the public, licensees in a mobile society, and the public trust.

 

[Charles A McBride]

Is the AOA involved in this? Is this an attempt by the AOA to undermine the NBEO?

How does one determine that the test isn't any easier or more difficult than in the past? -Charlie

 

[Michael W Ohlson]

Is the AOA involved in this? Is this an attempt by the AOA to undermine the NBEO?

How does one determine that the test isn't any easier or more difficult than in the past? -Charlie

I can’t speak for the AOA BoT. As a member, I hope our nat’l advocacy organization doesn’t publish or state unfortunate comments about optometry’s licensure examination. That weakens public trust, the opposite of advocacy.

Each item is tested prior to use (the un-scored questions) and scrutinized to death by the cmte and council members. The psychometric analyses criticized on the forum a while back provide such data. If one thinks a bit they see facts from misinformation and optometry politics.

 

[Lloyd Pate]

I can’t speak for the AOA BoT. As a member, I hope our nat’l advocacy organization doesn’t publish or state unfortunate comments about optometry’s licensure examination. That weakens public trust, the opposite of advocacy.

Each item is tested prior to use (the un-scored questions) and scrutinized to death by the cmte and council members. The psychometric analyses criticized on the forum a while back provide such data. If one thinks a bit they see facts from misinformation and optometry politics.

My question still is, who are the committee members?

 

[Michael W Ohlson]

My question still is, who are the committee members?

As I replied, NBEO used to share the names. Unfortunately, stakeholders lobbied those involved for information and such to the point that such efforts were discontinued. Your issue is with the professionalism of peers.

SMEs are free to share their involvement individually as desired. While I wouldn’t mind if I was a SME, I accept this policy.

 

[Alan David]

Still no word on who actually initiated this?
Did someone approach the Kentucky Board with this request?
KYCO? Big retail not finding licensed docs to fill their stores? Disgruntled students?
KY board members just disgusted with the recent NBEO missteps?

 

[Charles A McBride]

Still no word on who actually initiated this?
Did someone approach the Kentucky Board with this request?
KYCO? Big retail not finding licensed docs to fill their stores? Disgruntled students?
KY board members just disgusted with the recent NBEO missteps?

The word on the street is the Oregon Board of Optometry is also discussing it. It's strange. -Charlie

 

[Sandra Diaz]

The word on the street is the Oregon Board of Optometry is also discussing it. It's strange. -Charlie

KY board members just disgusted with the recent NBEO missteps?

My guess is that they are mostly fielding complaints about the test administration/results, not the test itself.
KY/OR grads chomping at the bit to start practicing, and being held up by the delay in getting their score reported.
Imagine failing by 1% and having to wait 8-9 month to even retest!

 

[Charles A McBride]

My guess is that they are mostly fielding complaints about the test administration/results, not the test itself.
KY/OR grads chomping at the bit to start practicing, and being held up by the delay in getting their score reported.
Imagine failing by 1% and having to wait 8-9 month to even retest!

Fielding complaints is one thing. Throwing out part 1 of the test is something else and that is what the talk is about. -c

 

[Michael W Ohlson]

The word on the street is the Oregon Board of Optometry is also discussing it. It's strange. -Charlie

I’ll let those state boards describe their missions and thinking.

Repeating, we have understanding and empathy for some of the NBEO criticisms. No one likes higher fees. The pass rates are low at several programs. There was a reporting error.

I’m less accepting of vague or incorrect criticisms. Being angry while wrong isn’t a path forward. For example, the PEPS launch/score release went as described in the years prior. Holds on scores and corrective measures due to candidate conduct investigations and violations are not delays. Ongoing misinformation efforts won’t assist the public, the candidates, or optometry.

If we wish to discuss fees, let’s include all the data on student debt. If we’re worried about completion of college due to costs, let’s include that data. See: ASCO website.

The institutional report demonstrates no testing problem; some colleges consistently do well.

The reporting error affected 10% of one cohort. NBEO acted transparently. Corrective measures were taken. Deep regret was expressed. Amends were made.

 

[Michael W Ohlson]

Restated, not knowing much and being angry isn’t professional. It’s harmful.

Violating conduct agreements on national licensure testing in health care is very bad. Don’t do that.

State boards are charged with public protection. Period.

The basic/biomedical sciences are accepted as essentials in licensure testing at the physician-level in the US. Not only is this a norm, but research supports such knowledge as critical to clinical decision-making, essential to better care in complex cases, and required for continuing competence over careers.

Any state board with concerns will immediately be invited to the testing center. Bring your questions. Watch Part III live. We’re prepared.

Conversely, parroting or acting upon misinformation, baloney, weird conspiracy theories… unwise for all.

None of the above is stated without empathy for debt-ridden candidates or regret for the reporting error.

 

[Mike Alvarez]

There was a thread started on this site questioning the need for the testing of basic science on national boards.

https://www.odwire.org/community/threads/must-clinical-ods-be-strong-in-basic-science.169197/

 

[Shaina Sullivan]

The word on the street is the Oregon Board of Optometry is also discussing it. It's strange. -Charlie

Charlie misunderstood this. The Oregon Board of Optometry is NOT discussing dropping part I or allowing Canadian boards.

 

[Michael W Ohlson]

Typical Charlie.

I’m aware that folks are approaching state boards over NBEO. My comments are consistent:

We care and deeply regret the reporting error incident. Without reservation. Without qualification. The organization isn’t perfect.

No one likes higher fees. Those not playing politics and choosing data will find increases in tuition, housing, food, etc. over a decade+. Donations to NBEO since 1951 by the stakeholders total $00.00. Candidates produce the revenue. New IT was due. A new Part III was demanded.

Examine the complete data for conclusions as professionals. Or react by discounting the biomedical sciences testing in 2025. Say anything and repeat it whether it’s factual or not. I wouldn’t. But I only get to manage myself.

Way to go, Charlie…

 

[Charles A McBride]

Charlie misunderstood this. The Oregon Board of Optometry is NOT discussing dropping part I or allowing Canadian boards.

I totally thought that's what I heard. Thanks for setting me straight.

 

[Michael W Ohlson]

I totally thought that's what I heard. Thanks for setting me straight.

The funny aspect is simply human. Optometry is quite small. Rumors, gossip, misinformation, exaggerations, and odd ideas zoom across the groups. I hear doozies.

Eventually you realize commonalities. ODs seldom to almost never keep a secret. People believe in conspiracies. The last thing that occurs is the homework.

Dr. Nelson said I’m the sort of personality that produced ABO. His analysis was off there. BC is for a post-residency specialty. There are defined aspects for that credential. Similarly, physician-level providers are tested in the relevant basic or biomedical sciences for licensure in the US. The basic sciences in optometry and ophthalmology are quite similar: optics, anatomy, physiology, biochemistry, immunology, microbiology, genetics, pharmacology, etc.

NBEO is one test with three parts. It’s not meant to be 2 of 3, etc.

Ignoring the important definitions and accepted standards is never good for optometry. It’s never been demonstrated. The opposite has been demonstrated.

 

[Steven E. Nelson]

The funny aspect is simply human. Optometry is quite small. Rumors, gossip, misinformation, exaggerations, and odd ideas zoom across the groups. I hear doozies.

Eventually you realize commonalities. ODs seldom to almost never keep a secret. People believe in conspiracies. The last thing that occurs is the homework.

Dr. Nelson said I’m the sort of personality that produced ABO. His analysis was off there. BC is for a post-residency specialty. There are defined aspects for that credential. Similarly, physician-level providers are tested in the relevant basic or biomedical sciences for licensure in the US. The basic sciences in optometry and ophthalmology are quite similar: optics, anatomy, physiology, biochemistry, immunology, microbiology, genetics, pharmacology, etc.

NBEO is one test with three parts. It’s not meant to be 2 of 3, etc.

Ignoring the important definitions and accepted standards is never good for optometry. It’s never been demonstrated. The opposite has been demonstrated.

What Dr Nelson said was that you’re the TYPE of person that gave us BC. So absolutely certain they’re right in the face of failure after failure and all evidence to the contrary and common sense, but forcing it on the profession no matter what whether the profession believes it’s properly done or not.

You, like them, take a very “you’re either in the tent pissing out or out of the tent pissing in” (a term given to me by a past President regarding BC and the AOA) approach to the rest of the profession. If you prefer literature, I’ll use Animal Farm where all of the animals are equal, but some are more equal than others….because you just “know so much more (whether it’s relevant or not)” that you don’t HAVE to listen to anyone else. You’ll shove your bad model down everyone’s throat because we HAVE to! We’ll lose the public trust, we’ll lose licensing, we’ll lose our autonomy, we’ll lose Medicare.

He stands by that.

Don’t reference me or misrepresent my words again.

 

[Charles A McBride]

Setting aside my libertarian tendencies that find intriguing the notion of completely abolishing licensure, once licensure is opted for, like anything, it ought to be done well. Students are being asked to demonstrate a certain level of learning and skills before beginning practice. This requires a test which should to demonstrate that. Careful standardization is an obvious goal. Making sure test questions are well written is important.

When the test center was moved to Charlotte, NC, I didn't love the idea of the students having to travel that far, but in terms of standardization it made a lot of sense. Yeah the fees have gone up but not ridiculously so in my opinion.

I've found Dr. Ohlson's explanations of the errors and time delays to be reasonable. -Charlie

 

[Charles A McBride]

Hey Mike, one question. You've said in the past that one of the psychometricians' jobs is making sure the test questions are "fair." Is there anything unrelated to merit in the word "fair" in this context? I mean, it's not like the NBEO would decide that life isn't fair for whatever group and arrange the test to give that group an advantage, right? (I'm embarrassed to have to ask, sorry.)

 

[Michael W Ohlson]

Hey Mike, one question. You've said in the past that one of the psychometricians' jobs is making sure the test questions are "fair." Is there anything unrelated to merit in the word "fair" in this context? I mean, it's not like the NBEO would decide that life isn't fair for whatever group and arrange the test to give that group an advantage, right? (I'm embarrassed to have to ask, sorry.)

Fairness is a broad topic in standardized testing. An important aspect is avoiding bias. One wants to avoid placing groups at advantages/disadvantages. It’s not a new topic. Language and culture can be issues even in math questions. This was not intuitive to me. The intention is to reduce biases so as to truly measure competence.

Sometimes these things are regional or time-related. Giant cell arthritis versus temporal arteritis? Epiretinal membrane versus cellophane maculopathy?

One can look at biases quite simply in optometry. Favoring those from certain schools, requiring unfamiliar instruments in practical exams, proctoring those candidates where relationships could reduce objectivity… much of the work is common sense. But the stakes are high; people are wired tight.

Everyone plays roles in increasing fairness. The cmtes and councils play strong roles; the test items are scrutinized extensively.

The other tenets, validity, reliability, and legal defensibility relate. You want the test to measure what you intend to measure. Consistency is necessary. Unfair assessments could/would be legally indefensible.

Testing accommodations and ADA compliance are significant factors in licensure assessments.

In terms of partisan politics, I’ve seen broad mixes in boards, cmtes, and councils, but never a disagreement based upon ideology. People stay focused on the work and seek to avoid such distractions. ARBO was similar. Folks tend to get along. When disagreements occur they’re often about poor communication or differing opinions on how to get to the desired outcome.

 

[Michael W Ohlson]

Shorter, better answer: You want to eliminate biases to the point that the only reason to fail is a lack of requisite knowledge or skill that the test is designed to measure. That can be difficult.

—

This leads one to the conclusion that the world is very different from the 1980’s and the five stand board exams I endured. While one might favor or reject past ways, high-stakes exams have to work in the present and near future. I’m convinced change will be a constant. PEPS will be revised much sooner than its predecessor, CSE. New tech, AI, scope changes… NBEO will need to be on sound footing for the public and our small profession. Hence the uncomfortable transition. It would be better for optometry to listen, speak, and reflect rather than squabble and politick. Divisiveness, grudges, weird beliefs about money… yikes.

 

[Mark Welding OD]

Hey Mike, one question. You've said in the past that one of the psychometricians' jobs is making sure the test questions are "fair." Is there anything unrelated to merit in the word "fair" in this context? I mean, it's not like the NBEO would decide that life isn't fair for whatever group and arrange the test to give that group an advantage, right? (I'm embarrassed to have to ask, sorry.)

Dr Nelson is a Psychometrician why not just ask him?

 

[Jeffrey Kiener]

Or just a psycho.


HAHAHAHAHAHAHAHAHAHAHA

 

[Steven E. Nelson]

Or just a psycho.


HAHAHAHAHAHAHAHAHAHAHA

Genius is so often unappreciated in its time.

 

[Michael W Ohlson]

The irony in the 2025 developments is a grin. When I nerded out on psychometrics here, a few became mocking and sarcastic. It’s not like I aimed at being a statistics person as a boy. I frequently poke gentle fun at the staff and consultants. We learn by doing.

The neurotic attention to detail produces the strong data supporting the NBEO processes. The absence of same would be bad.

This won’t alter folks acting on emotion. I get that politics and money become the foci. Ultimately the details will matter.

 

[Steven E. Nelson]

The irony in the 2025 developments is a grin. When I nerded out on psychometrics here, a few became mocking and sarcastic. It’s not like I aimed at being a statistics person as a boy. I frequently poke gentle fun at the staff and consultants. We learn by doing.

The neurotic attention to detail produces the strong data supporting the NBEO processes. The absence of same would be bad.

This won’t alter folks acting on emotion. I get that politics and money become the foci. Ultimately the details will matter.

Unfortunately, the OUTCOMES AND PERFORMANCE (and I’m not talking about passage rates before we go down THAT rabbit hole again) need to matter more.

What’s tiresome is that anyone looking at THOSE metrics are dismissed as “emotional” or “ignorant.” It’s part of what makes any idea that it’ll be fixed just folly.

 

[Mike Alvarez]

Shorter, better answer: You want to eliminate biases to the point that the only reason to fail is a lack of requisite knowledge or skill that the test is designed to measure. That can be difficult..

What biases? What is less biased than a standardized test?

The only part of the test I’d be worried about bias would be Part 3 since there’s a subjective component involved in the person observing you judging your performance.

 

[Michael W Ohlson]

What biases? What is less biased than a standardized test?

The only part of the test I’d be worried about bias would be Part 3 since there’s a subjective component involved in the person observing you judging your performance.

Questions on standardized tests can be biased based upon long lists of variables, such as race, sex, religion, region, age, college, culture, and more. This isn’t a new idea, but many decades old. This has not been a controversial aspect of NBEO, but one needs to be ahead of it, not on the bad side of it. Most issues would involve language or varied terminology. Boomer story: There are different ways to record lens power, kerotometry, etc. I was faced with having no damned clue how to answer. In that case, the assessment was not testing the intended goal. I guessed correctly and lucked out.

I concur on Part III. It takes very little to bias a practical exam. I often tell the story about preceptors arguing about how to do the cover test during lunch. Scoring based upon your own preferred method… not good. Many state boards used to ask where the licensee intended to practice. Yikes. Instruments used to vary dramatically, also throwing off candidates.

 

[Mike Alvarez]

Questions on standardized tests can be biased based upon long lists of variables, such as race, sex, religion, region, age, college, culture, and more. This isn’t a new idea, but many decades old.

I’ve certainly heard of people complaining about standardized tests being biased, but I’ve always believed standardized tests to be the least biased of any testing method available and the complaints to largely be overblown.

 

[Michael W Ohlson]

I’ve certainly heard of people complaining about standardized tests being biased, but I’ve always believed standardized tests to be the least biased of any testing method available and the complaints to largely be overblown.

There are those complaints requiring serious consideration. ADA and test accommodations are significant concerns in optometry school and licensure testing.

I’ve learned a bit about test biases. I didn’t know what I didn’t know. Reading and listening to experts in test development helped. NBEO is not considered bad in this area.

No test will be perfect. No one can name a perfect standardized exam. Legal defensibility is a big thing, however. People will name that.