This seems it should be very easy to validate. Force the AI to make minimal changes to the code under test, which makes a single (or as few as possible) test fail as a result. If it can't make a test fail at all, it should be useless.
Many times I've observed that the tests added by the model simply pass as part of the changes, but still pass even when those changes are no longer applied.
[0] https://www.aihero.dev/skill-test-driven-development-claude-...
[1] https://github.com/mattpocock/skills/blob/main/tdd/SKILL.md
It can still cheat, but it's less likely to cheat.