NASACT, NSAA Urge Release of 2025 Compliance Supplement, State Good-Faith Intent to Proceed Using 2025 Draft in the Absence of a Final Version

The final 2025 Compliance Supplement continues to be delayed. On October 29, the National State Auditors Association wrote a letter to the U.S. Office of Management and Budget express good-faith intent to continue using the 2025 Compliance Supplement version provided to the NASACT community by OMB on August 18, 2025, to perform fiscal year 2025 Single Audits. 

The annual Compliance Supplement is essential to achieving the purposes of the Single Audit Act. It establishes uniform audit requirements for federal awards, promotes sound financial management, supports the efficient and effective use of audit resources, and reduces administrative burden on non-federal entities. The 2025 Compliance Supplement reflects updates to more than 90 federal programs in response to significant changes in federal funding and priorities. Furthermore, it incorporates revisions, such as updates to the Uniform Guidance, that preclude continued reliance on the 2024 Compliance Supplement. These updates are necessary to ensure audits are conducted appropriately and consistently, enabling federal cognizant agencies to compare results across non-federal entities.

Perhaps most significantly, the 2024 Compliance Supplement identifies two programs, Coronavirus State and Local Fiscal Recovery Fund and Emergency Rental Assistance, as higher risk programs while the 2025 version does not. If auditors use the 2024 Compliance Supplement for 2025 audits, in most cases it will result in these two programs being unnecessarily audited which will waste taxpayer resources. 

Proceeding with the version of the 2025 Compliance Supplement provided by OMB in August is a necessary but problematic approach.

NASACT previously wrote a letter to OMB on August 13, 2025, to express our members’ concerns over the delayed release of the U.S. Office of Management and Budget’s 2025 Compliance Supplement.