greater governmental intrusion into education, and will needlessly increase the costs of educational testing for thousands of test-takers and their parents who are your constituents.

The goal of openness in testing can be and is being achieved without further legislation. That is how it should be. The New York State law is being carried out diligently by ETS and its test sponsors (see Appendix D).

By voluntary decision of the respective test-governing boards, the basic provisions of this law have been applied on a national basis. Further legislation such as H.R. 1662 is not needed or warranted.

To those who fear retrenchment from voluntary openness in testing, I say judge ETS and others both by our words and actions, now and in the future, and act accordingly. Don't legislate for the future to remedy

problems of the past which largely have been addressed. Don't impose regulation on an entire industry when the major segments of that enterprise already have acted voluntarily to meet the major goals of that legislation. If there is retrenchment, then act. If there isn't, why act at all?

A Challenge and a proposal. ETS is firmly and formally committed to the principle of openness in testing. To advance this principle for the future, I offer a challenge and a proposal:

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I urge all profit and nonprofit testing corporations, and
those agencies of government which test, to join with us

voluntarily in an industry-wide "Code of Fair Testing" for
educational testing nationwide.

I recommend that this voluntary "Code of Fair Testing" be
based on the new standards now being developed by the

American Psychological Association, the American Educational
Research Association, and the National Council on Measurement

in Education.

I further propose that a panel be appointed jointly by these three associations to monitor the industry-wide "Code of

Fair Testing" and I commit ETS today to cooperate fully with such a panel.

Thus, in addition to the actions which I have described affecting Educational Testing Service, the ETS Board of Trustees and I offer to join other testing corporations and agencies in a national effort to voluntarily promote openness in testing.

I am new to ETS. I have been very impressed by the commitment of the people who make up the organization and by the quality of services they provide to individuals and to institutions. ETS always has stood for quality and equality of educational opportunity and is dedicated to continuing this tradition in the challenging years ahead. I hope my testimony today and the policy position of the ETS Board of Trustees make

this dedication clear.

I thank you, Mr. Chairman and, through you, your colleagues on the Subcommittees, for the privilege of appearing before you today. I shall be glad to respond to your questions.

The debates over educational testing are part of the democratic. process in the United States. The Board of Trustees of Educational Testing Service has participated vigorously in these debates and has learned from them. As Trustees of a publicly chartered body, the Board recognizes its obligation to serve and be responsive to the worthy purposes which led to the establishment of Educational Testing Service thirty-four years ago.

It is the Board of Trustees' intent in establishing this Policy to make clear the corporate position of Educational Testing Service on matters which, in recent years, have been the subject of public debate. In taking this action, the Board is speaking only for Educational Testing Service for which, by law, it is responsible and accountable.

The Board of Trustees reaffirms its position that the public interest is best served by voluntary self-regulation in the educational testing field, subject to public and media scrutiny, rather than by governmental regulation administered by state or federal bureaucracies. It is our position that governmental regulation should be used as a last resort only when responsible educational bodies fail to respond reasonably to legitimate grievances of the public.

By official resolution voted on October 6, 1981, the Board of Trustees of Educational Testing Service formalized its support of the principle of openness in admissions testing. Specifically, the Board supports the recent actions of the College Board, the Graduate Management Admission Council, the Graduate Record Examinations Board, the Law School Admission Council and the TOEFL Policy Council on release of tests and test answers. In taking this position, the Board of Trustees incorporates those actions as policy for Educational Testing Service in the programs it conducts for the respective boards. We commit ETS to advance further, in concert with our contracting boards, the principle of openness in testing.

Openness in testing, however, involves more than test disclosure. The Board of Trustees, acting on behalf of Educational Testing Service, therefore takes the following actions:

· Adopts as policy for Educational Testing Service the "Public
Interest Principles" (attached), originally proposed for public
discussion on December 30, 1979.

• Approves as policy the "ETS Standards for Quality and Fairness"
(attached). These standards are fully consistent with and
indeed, in many respects, exceed the current testing and measurement
standards of the American Psychological Association, the American
Educational Research Association and the National Council on
Measurement in Education.

Endorses the process for systematic auditing by ETS of all testing
programs it conducts to assure adherence to the "ETS Standards
for Quality and Fairness." Such audits are performed on a cycle
so that each testing program is comprehensively reviewed at least
once every three years, with particular attention to provisions
in the standards to promote proper test use and to prevent test bias.
Directs the Trustee Committee on Public Responsibility to prepare
annually an accountability report, to be released publicly, which
is responsive to public concerns and evaluates actions taken by
Educational Testing Service in accordance with the "ETS Standards
for Quality and Fairness." In carrying out this responsibility,
the Committee will be assisted by a Visiting Committee of persons
from outside of ETS who are knowledgeable in the areas addressed
by the "ETS Standards for Quality and Fairness."

Approves establishment of a uniform complaint procedure for students
and other test-takers to provide ready access to Educational
Testing Service for student grievances about programs and services
provided by ETS. A Student Concerns Coordinator will be designated
in the President's Office to support this procedure, consult with
student organizations and otherwise promote communication with
students. The Board recognizes that ETS serves individuals as
well as institutions and will endeavor, in full collaboration
with its contracting boards, to resolve legitimate grievances
about programs and services provided by ETS.

* Formerly only administrative guidelines entitled, "Principles, Policies and Procedural Guidelines Regarding ETS Products and Services."

The Board of Trustees further encourages openness in testing for areas other than admissions testing, so that all test-takers will have full and open access to information about the purpose and content of the tests they take, the method of scoring, and the proper uses and limitations of the tests. ETS will work collaboratively with contracting boards and agencies to promote this objective.

The Board of Trustees further supports wide dissemination to schools, institutions of higher education and community agencies of new materials developed to help students and other potential test-takers understand the variety of tests developed by Educational Testing Service. These will include audiovisual materials, videotapes for use by public and cable television, and handbooks to be prepared for publication by the College Board and by Educational Testing Service. The aim of these materials is to make readily available to all students, regardless of economic status, high quality information about tests developed by Educational Testing Service.

It is the Board of Trustees' intent also to broaden access to test and research data which are under the control of Educational Testing Service. The Trustee Committee on Research and Development is developing policy recommendations to increase the availability of this information. The Board expects to act upon these recommendations at its April 1982 meeting. Further, ETS will work collaboratively with its contracting boards to facilitate expanded access to the test and research data which they control, in accordance with policies of the contracting boards. At the same time, the Board of Trustees reaffirms its long-standing commitment to protect the individual privacy of our test-takers in the release and use of test and research data.

Finally, the ETS Board of Trustees herewith urges all profit and nonprofit testing corporations in the United States to join with it in voluntarily developing an industry-wide "Code of Fair Testing" for the development and administration of educational testing nationwide. We recommend that this Code be based on the new standards being developed by the American Psychological Association, the American Educational Research Association, and the National Council on Measurement in Education. We further propose that a panel be appointed jointly by these three associations to monitor the industry-wide "Code of Fair Testing" and we commit ETS to cooperate fully with such a panel. Thus, in addition to the actions we have taken on behalf of Educational Testing Service, we offer to join other testing corporations in a national effort to promote openness in testing.

Attachments