As we move deeper into fall, many recipients of federal funding find themselves navigating a familiar yet frustrating challenge: the delayed release of the 2025 Office of Management and Budget (OMB) Compliance Supplement.
Traditionally issued in late spring, this critical document provides the framework for conducting Single Audits under Uniform Guidance. As of early October, however, the final version remains unreleased, leaving auditors and auditees in a holding pattern.
What’s Causing the Delay?
According to communications from the AICPA’s Governmental Audit Quality Center (GAQC), the delay stems from an administrative backlog at the OMB. While a draft version of the Supplement was made available to the GAQC in August, it has not yet received final clearance from OMB leadership. The GAQC has emphasized that this draft is for planning purposes only and cannot be used to issue final audit reports for fiscal years ending June 30, 2025.
Why This Matters
The Compliance Supplement is more than just a technical guide, it’s the playbook auditors rely on to test federal program compliance. Without it, auditors are prohibited from finalizing Single Audits, which has ripple effects for clients relying on timely audit reports for grantor deadlines, board reporting and continued funding.
For example, HUD multifamily projects may require an owner-certified submission by September 30, followed by an audited submission once the Supplement is released. Similarly, state agencies like the New Mexico Office of the State Auditor have issued due date extensions for entities requiring a Federal Single Audit.
Similar to what happened during the COVID-19 pandemic, when the compliance supplement was delayed and required some later revisions, we anticipate there will be an extension on the deadline, though this has not yet been formally communicated.
What We’re Doing at Schneider Downs
Our team has been proactive in using the draft Supplement to begin planning 2025 engagements. We’re also closely monitoring updates from the GAQC and the OMB. As noted in GAQC Alert #488, auditors should not issue June 30, 2025, year-end Single Audits until the final Supplement is released.
Looking Ahead
The good news? The OMB has indicated that no significant changes are expected between the draft and final versions. But until the final Supplement is published, issuing Single Audit reports risks noncompliance and potential repercussions from federal agencies.
We encourage our clients and colleagues to remain flexible and informed. While we await final clearance, consider separating financial statement audits from Single Audits where necessary to comply with lending and other requirements, and communicate early with funders about potential delays.
If you have questions or need help preparing for your audit in light of the delay, please reach out to your Schneider Downs engagement team.
About Schneider Downs Audit and Assurance Services
Schneider Downs’ engagement teams are hand-selected by our shareholders based on skill sets and experience and are available around the clock for consultation. Each attestation engagement is subject to our comprehensive quality control and risk management system, providing an independent review of audit opinions, related financial statements and significant underlying working papers, to ensure that the highest levels of professional standards are met.
To learn more, visit our Audit and Assurance page
