NASACT Urges OMB To Release 2025 Compliance Supplement

There’s being “fashionably late,” and then there’s “annoyingly late.” The Office of Management and Budget (OMB), in terms of issuing the 2025 Compliance Supplement, is entering the territory of being in a third category — “critically late.”

Along with our own grievances expressed about the delays in issuing the supplement in this forum, we now note that our friends at the National Association of State Auditors, Comptrollers and Treasurers (NASACT) have written to OMB to express its members’ concerns over the delay of the supplement, “which is vital to accountability and the timely submission of single audits.” Although the annual supplement has been issued prior to June 30 for the last three years at the behest of the audit industry, this year’s supplement has yet to be released.

In its letter, NASACT President and Idaho State Controller Brandon Woolf states that the supplement provides auditors with the audit objectives, suggested procedures and sources for compliance requirements, "which enables auditors to meet the standards required by federal agencies in an efficient and effective manner expected by the American public."

Citing OMB M-25-30, Ensuring Accountability: How We Oversee, Audit, and Improve, the letter emphasizes the importance of financial accountability. “Financial accountability is important to our members as well,” Woolf states. “To that end, our members have already started planning their audits and are committed to meeting the audit submission deadline required” by the uniform guidance (2 C.F.R. Part 200).

However, these audits cannot be completed without a published supplement. “Some of our member offices perform oversight engagements for colleges, technical colleges and universities which are required for reaccreditation,” Woolf adds. “Many of our members also audit the Student Financial Assistance (SFA) cluster of programs as part of the single audit. In one case, there are three such engagements due to a higher education accreditation association in early September. The auditor has been forced to perform SFA testing using draft compliance supplement guidance, but because they cannot release the audit without the final 2025 Compliance Supplement, there is a serious risk that these reports cannot be issued by the deadline, potentially affecting institutional reaccreditation.”

NACACT warns that a continued delay in releasing the 2025 Compliance Supplement will result in late single audits. “Given the potential negative consequences to federal fund recipients and the increased risk of untimely single audit reports, we respectfully request that OMB authorize the publication of the 2025 Compliance Supplement as soon as possible,” NASACT concludes.

We fully agree. To borrow a line from Ricky Ricardo from “I Love Lucy” when practicing to take Lucy to the hospital to have her baby, “The Time Has Come!”

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