Whether it matters or not, Geshe Kelsang Gyatso is definitely a Geshe.
He passed the exams and got the qualification. He has explained this himself in teachings, also once saying that he did not go on to get the Geshe Lharampa degree awarded to the greatest scholars, but that he got the regular Geshe degree. ....
See what it says on Wikipedia (as well as its sources):
Geshe Kelsang Gyatso was born on Dharmachakra Day (the 4th day of the 6th month of the Tibetan lunar calendar) 1931 in Yangcho Tang, eastern Tibet. His lay name was Lobsang Chuponpa. His ordination name "Kelsang Gyatso" means "Ocean of Good Fortune". His mother made great sacrifices to enable her son to attend the Ngamring Jampa Ling Monastery because he showed interest and aptitude from an early age. He joined the monastery when he was 8 years old and later described memorizing the Medicine Buddha Sutra:
......
Later Geshe Kelsang studied for 15 years at Sera Monastery near Lhasa,[8][9] one of the great Gelug monastic universities of Tibet. According to Cozort, Kelsang Gyatso is "a highly trained geshe."[10] At Sera Je, he successfully completed the full Geshe studies of five large philosophical texts. After passing two examinations at Tashilhunpo Monastery in Shigatse, he received his Geshe degree.[11] He was a member of the Tsangpa Khangtsen, one of the fifteen houses at Sera Je monastery. Contemporaries at Sera Je included Geshe Lhundub Sopa, Geshe Rabten, and Lama Thubten Yeshe.
Whether Kelsang Gyatso is a qualified teacher is out of question. I heard that during the days in India, while other young tulkus/geshe candidate went for prilimage/relax during break, Kelsang Gyatso just like doing meditation. He has his own style and be respected by his folks.
But it worth to make it clear whether Kelsang Gyatso is a Geshe from the 3 monastery's view-point.
My understanding is that after leaving the monastery, tulkus seldom refer themselves as 'Geshe XX ', but XX rinpoche. For non-tulkus, it seems be tradition that if he got the geshe degree, in official environment, we call him Geshe XX(say Geshe Rabten), if not, we call him Lama YY(say Lama Yeshe), this is for respect of the 3 monastery system and we are using strict definition of 'geshe' here(ie. those who spent years in the monastery and went through the whole curriculum, normally 20 years study for non-tulku). But in non-official environment, we can call any lama 'Geshe' as far as he spent some years in the monastery for study(ie. using loose definition of 'spiritual friend' here)
From above quote, brief biography of Kelsang Gyatso is:
- born on Dharmachakra Day 1931
- joined the Ngamring Jampa Ling monastery when he was 8 years old
- studied for 15 years at Sera Monastery near Lhasa
- After passing two examinations at Tashilhunpo Monastery in Shigatse, he received his Geshe degree
It is quite strange to me why Kelsang Gyatso studied in Sera Je but 'got passing two examinations at Tashilhunpo Monastery in Shigatse'. Let's check the 'shortest path' assuming Kelsang Gyatso didn't spend any time in his home monastery Ngamring Jampa Ling : 1931+ 8+15= 1954. So if Kelsang Gyatso did spend 3 years in his home monastery(which is quite usual), after his 15 years of study in Sera Je, it was 1957!
This timeline analysis provide some hint on what might happen:
Kelsang Gyatso has completed most of his academic training in Sera Je of Lhasa(15 years), but due to the turmoil in Lhasa in 1957, his study was terminated, as for non-tulku it should be total 20 years study on the geshe program. Kelsang Gyatso might not fled to India immediately (which might be reason he 'passed two examinations at Tashilhunpo Monastery in Shigatse'), but anyway he did it after-wards. So it was early 1960s when Kelsang Gyatso arrived India, and by that time the exile community was in a mess, the 3 monasteries was not re-built yet(they were re-built in early 70s). By reading biography of other senior lamas, it looks that during 60s-early 70s, for purpose of maintaining the lineage, although monks in exile still studied hard, but the environment was not as like Lhasa, so there was a lot of exemption as compared with the Lhasa program, anyway some monks were granted with 'Geshe degree' after completion of the program, and they were required to do a 'graduation offering' to other monks according to tradition. Kelsang Gyatso should be one of those granted with this title and be accepted by the sangha as a geshe (in strict definition according to 3 monasteries) during this period.
So Kelsang Gyatso is a geshe, nothing wrong to call him 'Geshe Kelsang Gyatso' in official environment. He completed the 'program' during 60s and be granted with this title by then(the graduation offering to monks is the 'signature', not any certificate, who had the $/spare time to print a 'certificate' during this period, when they even don't know where to go for settling down..?). It was a special time special program, which not like the 3 monastery system as re-established in India now.