What is Self-Certification?
Self-certification is one of the compliance monitoring tools MRO uses to assess compliance with NERC Reliability Standards. As part of this process, utilities companies (also referred to as registered entities) assess compliance with NERC standards and requirements using prescriptive guidance from MRO and providing substantiating evidence to demonstrate compliance.
What is the goal of Self-Certification?
Self-certification provides MRO reasonable assurance of registered entity compliance based on the self-assessment completed by the entity of the NERC Reliability Standard and/or requirement(s) in scope. MRO staff assess the self-certification results to verify the accuracy of the registered entity’s determination.
What are the expectations?
The following criteria must be met when completing a self-certification:
Performance
Individuals performing the self-certification must understand the request and obligations placed upon them and seek assistance from MRO staff if there are questions. Responses must be truthful and honest and the entity’s designated Primary Compliance Contact needs to have oversight of the activity.
Assessment
The assessment instructions for each NERC Reliability Standard and requirement in-scope for the self-certification must be adhered to, with the guidance provided in the Self-Certification Worksheet.
Documentation/Evidence
Completion of the Self-Certification Worksheet and the submission of evidence demonstrating compliance are required. Original, unredacted evidence in Word, Excel, or PowerPoint, etc., format should be provided and uploaded to the ERO Secure Evidence Locker (SEL). Testing documentation and any supporting notes should also be submitted in the native non-PDF format. Please note that compressed files (e.g., ZIP, ZIPX, SIT, GZ, TAR, RAR, ARJ, 7Z, 7ZX) as well as file types that can contain executable malware are prohibited from being uploaded to the SEL. MRO may request additional evidence to support the registered entity’s determination as well as subject matter expert interviews for evidence clarification, if appropriate.
Submission to MRO in Align
Entity staff performing the self-certification submittal should have access to Align and the ERO Secure Evidence Locker (SEL).
- Assign the standard requirement to the appropriate staff as necessary. (Please note that MRO has come across issues where assigned individuals are no longer with the company.)
- Download the Self-Certification Worksheet from the “Featured Documents” section of MRO’s Self-Certification web page.
- Fill out the Self-Certification Worksheet per the instructions in the worksheet.
- Upload the completed Self-Certification Worksheet and supporting evidence to the ERO SEL.
- Registered entities are required to submit a Self-Certification Worksheet for all determinations. This includes responses of “Do Not Own” or “Not Applicable.”
- Answer the questions listed in the “Self-Cert Assessment” section in Align.
- “Save Draft” allows future changes to the responses and “Save” is the finalized response.
- Once all the requirements have responses, the self-certification record can be submitted for Compliance Enforcement Authority (CEA) review by clicking on “Update.”
Additional Information
- MRO posts the standards and requirements in-scope for the next year’s self-certification activities on MRO’s Self-Certification web page by December 1 of each year.
- Registered entities are selected to receive a self-certification based on one or more of the following criteria:
- Registered for at least one of the appliable functions associated with the standard requirement(s)
- Registered entity’s risk level
- Other criteria deemed by FERC, NERC, and/or MRO
- Notification of registered entity selection for a self-certification is sent out via Align each year on the following dates:
- February 1
- May 1
- August 1
- November 1
- Please note: registered entities can view the self-certification and begin preparing responses but cannot submit in Align until the start of the following quarter.
- If the registered entity determines non-compliance for the self-certification:
- Mark “Non-Compliant” in Align and submit a draft “Finding.” (Expand the Findings portion of the self-certification record and create a new finding by clicking the + symbol next to the associated requirement.)
- Once the initial Finding is created, additional changes can be made from the “Self-Reports and Logs” module.
- The “Finding” must be created before submitting the self-certification to MRO.
- If the registered entity does not respond to a self-certification, a Potential Non Compliance (PNC) for the standard requirement(s) will be created following MRO’s process.
- If the registered entity cannot meet the due date of a self-certification, the registered entity must reach out to the self-certification lead before the due date to see if an extension can be granted. Extensions are for extenuating circumstances and are granted at the discretion of MRO staff.
- The registered entity does not need to submit an attestation for a self-certification via Align.
- If the registered entity determines the requirement(s) in the self-certification are not applicable, the self-certification lead should be contacted before answering and submitting “Non-Applicable” in Align.
- The self-certification lead and contact information is indicated in the “Instructions” section of the self-certification in Align.
Additional outreach can be found in the following MRO Presentation: Align and Secure Evidence Locker (SEL) Webcast
Align Training for Registered Entities: NERC Learning – Training Material for NERC Professionals, 0.9 – Self-Certifications
References: NERC Rules of Procedure, Appendix 4C – 4.2 – Self-Certifications
– Sanja Trajkovska, MRO Senior Compliance Engineer, O&P and Karen Yoder, MRO Principal Compliance Engineer, CIP