At least a dozen top Russian winter sports athletes, including some publicly implicated in the Sochi 2014 doping scandal, were not tested by the Russian Anti-Doping Agency in the first 10 months of this year, according to a list published by RUSADA several days ago.
The continued gaps in testing after two years of supervised reform efforts -- coming after many more years of corruption and dysfunction -- emerged as the World Anti-Doping Agency leadership convenes in Seoul, South Korea, this week to decide whether RUSADA should be fully reinstated. The information could put more pressure on the International Olympic Committee as it considers whether Russian athletes should be eligible to compete in the Pyeongchang Games three months from now. Sanctions against Russia are expected to be announced in early December.
More than 2,500 athletes from winter, summer and Paralympic sports and the number of times they were tested from January through October 2017 are listed in the document quietly posted on RUSADA's website a week before the Nov. 16 WADA Foundation Board meeting in which RUSADA compliance with WADA standards is a top agenda item.
RUSADA has conducted 3,782 tests thus far in 2017. Two-thirds of the athletes on the list were tested only once. Less than 12 percent (299 athletes) were tested three times or more. The total test numbers are up from 2,556 in 2016 but in both quantity and focus are inadequate for a country with the resources -- and past history -- of Russian sport, according to several sports and anti-doping officials contacted by ESPN.
U.S. Ski and Snowboard Association CEO Tiger Shaw called the list evidence of "a mockery of a system.'' "Gross counts of tests conducted don't really fit the bill,'' he said, noting that a single test in a calendar year would usually indicate a low-level athlete rather than one capable of racking up World Cup points or a podium placement.
It was unclear why RUSADA elected to publish the list, as it was encouraged but not required to do so by WADA.
An ESPN analysis shows that athletes missing from the RUSADA testing list include world-class performers and athletes returning from suspension or under provisional suspension in 2017, all of whom would normally be target-tested by a national anti-doping agency operating under best practices. A few prominent examples:
• Top Russian biathletes Anton Shipulin, who finished second in the overall 2016-17 World Cup standings, and Irina Starykh, a double gold medalist at the 2017 European Championships who served a previous doping suspension. Several other biathletes who compete on the World Cup circuit were absent from the list.
• Cross-country skiing Olympic gold and silver medalists Alexander Legkov and Maxim Vylegzhanin, who were recently stripped of their medals and results by the IOC, and their teammate Evgeniy Belov, whose Sochi results also were annulled. All three competed for part of the 2016-17 season. Because FIS, skiing's international governing body, has not yet sanctioned the athletes, they currently are free to compete in non-Olympic races, and Vylegzhanin raced in Finland last week.
• Current 500-meter and 1,000-meter speedskating world-record holder Pavel Kulizhnikov, who missed the Sochi Games due to a doping suspension, two-time world 500-meter medalist Ruslan Murashov and Sochi figure skating gold medalist Adelina Sotnikova, who was recently cleared in the IOC's doping investigation, also were missing from the testing list.
It is theoretically possible that athletes who went untested by RUSADA were tested multiple times by their international federations. The International Biathlon Union now includes all Russian athletes competing in their events in its registered testing pool of elite athletes.
Some Russian athletes might have deliberately sought to train or base themselves outside the country in order to be tested in a more credible system, Institute of National Anti-Doping Organizations founding CEO Joseph de Pencier noted, seeing as that could weigh in their favor when individual eligibility is examined. But there is no way for observers to know how much an athlete is being tested by an international federation unless it discloses names in its statistical reports, and most do not.
FINA, swimming's world governing body, is an exception. According to statistics posted on its website, Russian swimmer Yulia Efimova, whose verbal and aquatic battle with American teenager Lilly King sparked headlines at Rio 2016, has been tested 14 times this year by FINA -- nine of those out of competition -- while undergoing just one test by RUSADA.
However, with the question of Russian eligibility in Pyeongchang 2018 looming, the seven international winter sports federations are under the microscope, and none publishes the names of athletes tested. Athlete test histories are available in the United States, and reaction from U.S. officials and former athletes was incredulous.
Bill Demong, the retired 2010 gold medalist in Nordic Combined who now heads USA Nordic, underlined the sense of betrayal felt by athletes who submit their 24/7 whereabouts for testing.
"Having endured years of being liable for when I decide to get up and go train or take a vacation in the spirit of transparency, it pains me to see that Russian athletes who are training to win medals and also some who have already tested positive are not being tested with nearly the kind of frequency I and other American athletes are subject to,'' said Demong, who was tested as many as 20 times in a single year by the U.S. Anti-Doping Agency.
Athlete activist Lauryn Williams, the first U.S. woman to win medals in Summer (track and field) and Winter (bobsled) Games, said, "This further supports the idea that Russia should not compete in Pyeongchang, and they should have to start fresh.''
World Cup-level athletes in virtually every skiing discipline, including ski jumping and freestyle, were absent from the testing list. Among men's and women's hockey players listed, just 10 of 130 had been tested more than once.
USADA CEO Travis Tygart said he and his staff were still studying the list and called the testing numbers "absolutely unacceptable. They have the resources. They just need the will.'' But, he added, "It's not those athletes' fault. They deserve better.''
The low volume of tests per athlete raises questions about biological passport collections because it is generally accepted that a minimum of three or four tests per year is required to track biomarkers that could indicate blood doping or steroid use.
Testing rates varied significantly among winter sports. On the whole, RUSADA tested Russian bobsled and skeleton athletes more than their counterparts, with 13 of the 20 top athletes on the list undergoing three or more tests.
The RUSADA list does not distinguish between in-competition tests and unannounced out-of-competition tests, which are more effective.
An email query sent to RUSADA on Tuesday was not immediately answered.
WADA's decision on RUSADA's compliance status has major implications for upcoming international competition.
If RUSADA is not declared fully compliant, the International Paralympic Committee will bar Russian athletes from competing at the March 8-18 Winter Paralympic Games in Pyeongchang. The IPC, citing McLaren's evidence of a massive organized sports doping scheme, split with the International Olympic Committee and did not permit the country to participate in the Rio 2016 Summer Paralympic Games.
By contrast, the IOC allowed most of the Russian delegation to compete at Rio 2016 after handing off the responsibility for vetting individual athletes to international sports federations.
The IAAF, track and field's world governing body, has said it would require RUSADA compliance before lifting the ongoing two-year suspension of the Russian Athletic Federation, which has resulted in most Russian athletes' missing the Rio Games and the 2017 world championships. Some have competed under a neutral designation.
RUSADA was suspended in November 2015 and has struggled to meet WADA's standards for compliance since then, in terms of both testing infrastructure and governance. WADA had to pressure RUSADA to compel IOC member and retired pole vaulter Yelena Isinbayeva, a vocal critic of the independent doping investigations and sanctions against Russia, to step down shortly after she was appointed to chair the agency's board, citing a requirement that board members be independent.
The UK Anti-Doping Agency and other outside experts were brought in to oversee, strengthen and monitor testing during a transition period. Their task was initially impeded by a lack of trained doping control officers in the country, test evasions, athletes' failure to properly enter "whereabouts'' information and a lack of access to closed military cities. UKAD's formal role ended in June, after it helped develop a test distribution plan for the rest of this calendar year.
WADA officials have noted signs of progress in the last year, but gaps remain in its published "road map" to compliance. The issue of access to closed cities has not been fully resolved, and samples stored in the Moscow lab have not been made available to investigators. An electronic laboratory database sought by WADA was delivered by a whistleblower. The larger issue of Russian "acceptance" of McLaren's findings keeps blowing up in rhetoric by both sports and political officials.
ESPN Content Associate Alex Eliasof contributed to this report.