Six-Month Delay in Guide to Audits

The Office of Management and Budget (OMB) has released the 2025 Compliance Supplement for Single Audit Act audits. Its issuance as Appendix XI to 2 C.F.R. Part 200 was formally announced in the Federal Register on November 26, 2025 (90 Fed. Reg. 54400). A full copy of the Compliance Supplement is available on the White House’s Guidance website here.

High-Risk Programs

Under Part 8 of the 2025 Compliance Supplement, several programs continue to be designated as “high risk” for purposes of Type A program determination under 2 C.F.R. § 200.518. These include:

• Medicaid (ALNs 93.775, 93.777, and 93.778), and

• The Department of the Interior’s Abandoned Mine Land Reclamation Program, which received significant additional funding under the Infrastructure Investment and Jobs Act (IIJA).

Programs designated as high risk are more likely to be selected for compliance testing during the Single Audit.

Consistency with October 2024 Uniform Guidance Amendments

The 2025 Compliance Supplement replaces the term “nonfederal entity” with “recipient” and “subrecipient.” This is consistent with definitions adopted in the updated 2024 Part 200 changes.

2025 Supplement Effective Date and Applicability of 2024 Part 200 Changes
(Including HHS Adoption of Part 200)

Due to the differing implementation dates used by federal funding agencies for the 2024 Uniform Guidance revisions, the 2025 Compliance Supplement provides specific instructions to help auditors determine whether to apply the revised 2024 Uniform Guidance or the pre-2024 version of the Uniform Guidance to the awards and subawards under audit.

Transition from FSRS to SAM.gov for FFATA Reporting

The 2025 Compliance Supplement also addresses the federal transition from the now-retired FSRS reporting platform to SAM.gov for reporting first-tier subawards of $30,000 or more, pursuant to the Federal Funding Accountability and Transparency Act (FFATA) and the regulations at 2 C.F.R. Part 170. The Supplement includes updated instructions for testing compliance with these reporting requirements.

Feldesman LLP will continue to monitor and assess the impact of OMB’s release of the 2025 Compliance Supplement.  If you have any questions, please contact Phillip Escoriaza.

Stay current on key federal grants updates by joining Feldesman’s Monthly Briefings for Federal Grantees: Key Updates and Developments webinar. The next session will take place on December 16, 2025 at 1 p.m. ET.