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The administrator of the North American Veterinary Licensing Examination will initiate an independent audit in the wake of allegations that the test required for veterinarians to practice in the United States and Canada is biased.
In a brief statement, the International Council for Veterinary Assessment said this month that it is acting in response to questions from members of the veterinary community "around how the NAVLE is developed, administered, and scored."
Current misgivings about the 360-question, multiple-choice exam were articulated in October in a letter, known as a pre-litigation notice, sent by a San Francisco law firm to the American Veterinary Medical Association, which uses NAVLE performance data in its accreditation oversight of veterinary schools. The letter alleges the exam is "potentially anticompetitive, fraudulent, and discriminatory," citing "pronounced, persistent, and unexplained disparities in NAVLE outcomes related to race and ethnicity."
Specifically, the letter said impacted test-takers are those with Hispanic surnames and/or who graduated from Tuskegee University, the only veterinary school at a historically Black university and the program with the most diverse student body in the U.S.
The ICVA rejects the claims in the notice. "We responded, through legal counsel, to make it clear that the accusations in the pre-litigation letter had no basis in fact," Dr. Heather Case, ICVA chief executive, told the VIN News Service in an email. "We expect the independent third-party audit to affirm the integrity of the NAVLE. … Our goal is to provide clear, objective validation that our processes are rigorous, fair and aligned with best practices."
The pre-litigation notice was leaked and posted on Reddit, a social news-aggregation and discussion platform. In November, a self-described "coalition of impacted Black veterinary candidates" and the Latinx Veterinary Medical Association each released to the public letters to AVMA representatives expressing concern and calling for an audit.
Dr. Mitsie Vargas, president of the Latinx VMA, said she's "relieved and happy" that the ICVA is moving forward with an audit. The coalition was less satisfied, according to a representative, who said that the brief announcement has done little to quell its members' concerns.
Kelly Dermody, an attorney at Lieff, Cabraser, Heimann and Bernstein who wrote the pre-litigation letter, did not respond to emails or a voicemail from VIN News.
Through a spokesperson, the AVMA provided a statement to VIN News supporting ICVA's decision to bring in an auditor.
"Given the critical importance of the NAVLE to the veterinary profession, the AVMA believes that an independent evaluation would help assure the profession that appropriate steps are being taken to ensure the NAVLE remains valid, reliable, fair, and follows best practices in assessment," the AVMA said, adding that "such a review should strengthen confidence in the process and reinforce our shared commitment to maintaining the highest professional standards."
'Corroborated accounts'
In the pre-litigation letter, Dermody says her firm is representing a group of Black and Hispanic U.S. citizens with "stellar academic records" at accredited veterinary schools who failed the NAVLE "despite robust preparation and predictive pre-exam performance."
She says the firm had conducted an investigation that included reviewing "scores of records, interviews with dozens of candidates and a review of publicly available data."
The letter claims "multiple corroborated accounts" found issues in the questions faced by failed test-takers. For example, some said they got nonsensical or poorly constructed test questions, multiple-choice questions with more than one correct answer, or questions with content outside the exam blueprint, such as questions about unusual animals like camels or sharks.
The "blueprint" defines the topics, species and competencies that every exam should cover, according to an ICVA article on how the exam is created, administered and scored.
The letter, as leaked, does not elaborate on or provide evidence to support the claims.
In it, Dermody says the ICVA does not follow standard protocols used in licensing exams for nurses, physicians and attorneys. She claims that administrators of these tests use independent audits, among other measures, to ensure fairness and detect bias.
VIN News contacted organizations that administer professional licensing tests for the three professions to ask about their use of independent audits. Two responded to the question.
Kara Smith, chief product officer at the National Conference of Bar Examiners, which develops licensing tests for lawyers, said, "NCBE regularly engages independent third-party psychometric organizations to support complex technical work such as validation studies, scaling and equating analyses, and major exam transitions." The response was emailed to VIN News by an NCBE spokesperson.
Psychometrics is a field of study concerned with measurement. Some psychometricians conduct validation studies and fairness reviews of professional exams.
A spokesperson for the National Board of Medical Examiners (NBME), which develops and scores the U.S. Medical Licensing Examination for physicians, said the organization "has staff psychometricians who utilize statistical tools to analyze test item performance."
In the pre-litigation notice, Dermody sought a meeting with the AVMA and "appropriate stakeholders" to discuss steps to ensure fairness and compliance with all applicable laws. "Your organization," Dermody writes, "and your sister organizations, are now on notice that the NAVLE, as currently designed and administered, fails to meet the minimum standards of transparency, validity, and fairness required for a high-stakes licensure examination, and that its use is inflicting foreseeable harm."
In addition to the AVMA and the ICVA, the letter calls out the NBME. While it focuses on exams for physicians, the NBME is also responsible for "key components" of the NAVLE, including item editing, technical review, and scoring and score report creation, according to Case. She said the organization will be directly involved with the audit.
Demands in the pre-litigation letter include safeguards to ensure that all candidates receive consistent and fair exam questions, raw grade reporting and an external audit of exam construction and scoring. In case of future legal action, the letter claims damages could include "lost earnings and employment opportunities, sunk educational costs, exam and preparation expenses, and substantial emotional distress."
Affinity groups weigh in
The first that many in the veterinary community heard about the allegations against the ICVA was through an open letter to Dr. Michael Q. Bailey, AVMA president, entitled "A Respectful Appeal for Moral Leadership in a Moment of Crisis," from the coalition of impacted Black veterinary candidates. A copy was emailed on Nov. 10 to the Veterinary Information Network, an online community for the profession and parent of VIN News. The pre-litigation letter was attached.
The letter invokes Bailey's unique role in the profession‚ as a Tuskegee alum and the first Black president of the AVMA — "a man whose own story embodies what fairness in this profession should look like," it says. "You did not create the NAVLE system, yet its outcomes fall hardest on students who look like you once did."
The questions about the NAVLE come amid controversy at Tuskegee. The exam pass rate for its graduating seniors, which was 90% in 2017, has been below 80% for the past six years. (The pass rate for all accredited schools was 89% this year.) The consistent subpar performance is one reason the program is facing the loss of its accreditation.
The open letter calls the allegations of "racially motivated score manipulation and systemic fraud ... shocking but tragically familiar." It calls for a "straightforward remedy" of an independent audit of NAVLE raw data, saying, "Such transparency is not radical. It is a basic safeguard every profession owes its candidates and the public."
An unidentified person or persons who responded to reporter questions that had been emailed to the letter's sender address wrote that they declined to reveal their identities out of fear they would be targets for retaliation.
The coalition representative said the group was not involved in the drafting of the pre-litigation letter. Asked how they came to discern what they believe to be a discriminatory pattern in NAVLE failure rates, they said:
"It was an evolving process. There were suspicions for years, and slowly, people began to come together. Then there was Jill Lopez's petition," the representative said, referring to a petition on Change.org posted on May 25 by Dr. Jill Lopez, CEO of Vet Candy, a media company focused on the profession, and a Tuskegee alum. The petition, which had 707 signatures around noon on Dec. 26, called for a third-party "review of the NAVLE to ensure it is fair, transparent, and clinically relevant."
Although the petition did not allege bias, "it was a catalyst as groups of color began to realize that the 'exam issues' seem to have impacted them uniquely," the coalition representative said. "The exam can't be both as flawed as the petition describes and yet have a 100% pass rate at schools like Texas A&M."
They described this as a "watershed moment, when people realized that nothing about the ICVA is what it appears: no audits, no manuals, none of the transparency of other exams. A total and absolute obsession with secrecy. Then the pre-litigation letter, and then it kinda snowballed from there."
The ICVA "strongly disagrees" with this characterization. Case said the organization selected the NBME to work on the veterinary exam "because of its expertise and excellence in creating high stakes licensure exams in the medical profession." She also said the ICVA produces public documents about how the exam is designed, tested and administered, such as a candidate bulletin, and implements an "in-depth practice analysis" every seven years to determine whether the exam accurately assesses the knowledge needed for entry-level veterinarians.
The Latinx VMA followed the coalition with its own statement signed by Vargas, a 1994 Tuskegee graduate. Published in Vet Candy, sent to the AVMA Board of Directors and cc'd to veterinary state boards around the country, the statement requested support for an independent third-party audit.
"Members of our community, along with colleagues across the profession, have raised ongoing concerns about fairness, item construction, and potential bias within the NAVLE," Vargas wrote. "While many of these concerns remain unverified, the persistence of these reports, combined with the experiences shared by examinees, underscores the need for greater transparency." The Latinx VMA was established in 2020. It has more than 200 members and clubs at 25 veterinary colleges, according to Vargas.
She told VIN News that questions about the exam came to her attention when she was contacted by students and colleagues concerned with what appears to be the unusually high number of students with Hispanic last names failing the test.
"This was not an attack or criticism but a call for transparency," she said.
Early days for the audit
The ICVA's announcement described the audit as being in early stages. In mid-December, Case told VIN News that the specifics of the audit, including timing, were not yet finalized.
Case also said that the NAVLE has been audited once in the past.
"In 2020, the California Veterinary Medical Board, through the Department of Consumer Affairs' Office of Professional Examination Services, reviewed the NAVLE's suitability for ongoing use in California's licensing process," she said. "It confirmed that the NAVLE's development, administration, and scoring fully met all applicable professional guidelines and technical standards."
She said the ICVA will release findings from the new audit once it concludes. "Additionally, we will detail any actions ICVA plans to take to address the recommendations, if any, made by the independent third-party auditors," she said.
In other related news, the ICVA announced on Nov. 17 that it is making a one-time change to its retake policy.
Candidates have been able to take the NAVLE up to five times in a timeframe of their choosing before being locked out of future attempts, with an opportunity to appeal to take the test one more time.
Beginning with the March 2026 testing window, all candidates will be granted five new opportunities to take the NAVLE, regardless of their prior testing history, essentially clearing the slate for all test-takers.
"ICVA recognized the challenges of applying the waiver process uniformly across all cases and jurisdictions and eliminated it to ensure a consistent and impartial policy for all candidates," Case told VIN News.
Testing for the 2025-2026 NAVLE exam cycle is already underway, with the first window from Oct. 15-Nov. 15, 2025, complete. There are two more testing periods for this cycle, March 1-21 and July 13-Aug. 8, 2026.