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Propensity score analyses assumes no methodological issues with confounding covariates. Yet, assumed observed covariates may be indicators of latent variables which possibly contain measurement error through cross sectional non-invariance between treatment and control groups. This study conducted a Monte Carlo simulation to analyze several latent variable proxies when intercept measurement non-invariance or loading measurement non-invariance was not accounted prior to estimation of the propensity weight. The latent variable proxies included: individual indicators, sum scores, conclusive factor scores, and inclusive factor scores along with the latent variable. Simulation results support the need for strong invariance regardless of proxy, but loading non-invraince was unrelated to bias in the average treatment effect.