Let’s just get this out of the way: if your 179D provider is asking you—the designer—to do all the field work and then asking the contractors to sign the inspection and certification statements… you’ve got a problem.
And not just a small problem. A full-blown, out-of-compliance, IRS-audit-triggering kind of problem.
Yet somehow, this is becoming a business model for some firms out there. No names mentioned, but here’s the routine:
1. The provider requests that YOU (the client/designer) go out and gather all the site data.
2. Then they ask the HVAC contractor, or the lighting sub, or whoever was handy on the project to sign off on the certification statement.
Read that again.
Not only is this wildly inappropriate per IRS bulletin guidance, but it also makes your life harder for no reason. You’re doing all the heavy lifting, putting your name (or your subs’ names) on the line, and what do you get in return? A piece of paper that may not even hold up if the IRS comes knocking.
Let’s talk common sense here. Why would anyone pay a “179D specialist” just to do nothing but shuffle forms and create headaches? If your provider isn’t:
● Coordinating the site visit themselves,
● Preparing the full engineering analysis,
● Handling the certification using their own licensed professional, and
● Only asking you for already-existing plans/specs or to help get an allocation letter…
…then what exactly are they being paid for?
And here’s the kicker: under no circumstance should anyone on the design or contracting team be the one signing off on the 179D certification or inspection. That’s not just incorrect—it’s bizarre. It’s like letting the chef at a restaurant write the health inspection report.
So why is this happening?
● Are designers just unaware that this approach is both non-compliant and completely backwards?
● Are these providers just the most charismatic, smooth-talking sales reps in the industry?
● Is it just inertia and nobody wants to change the process?
Whatever the reason, it needs to stop.
We now have IRS audit guidelines. This isn’t the Wild West anymore. The best 179D firms follow standard protocols—because that’s what protects clients, holds up under review, and keeps things clean, compliant, and painless.
So here’s the bottom line: If your provider is making you work for your own benefit, while putting you at risk of failing an audit… fire them. Find a firm that knows what they’re doing, does the work for you, and signs the certification themselves, as it was always meant to be.
Because you deserve better than cleaning up someone else’s compliance mess.
