OMB Releases Final 2025 Compliance Supplement
It’s here! Just when we all about gave up, the Office of Management and Budget (OMB) has FINALLY announced the issuance of the 2025 OMB Compliance Supplement (Appendix XI to 2 C.F.R. Part 200), albeit about a half a year late. Something to be thankful for this Thanksgiving!
The 2025 supplement applies to fiscal year audits that cover any period beginning after June 30, 2024. This version amends the 2024 supplement by adding two programs, deleting seven programs and changing testing requirements for 17 programs. In addition, due to the issuance of the 2024 revisions to the uniform guidance, the 2025 supplement includes two sections on suggested audit procedures for the Part 3 compliance requirements — one for awards following the prior version of the uniform guidance and one for awards that follow the 2024 revisions. Along with the audit guidance for each major program, the supplement provides specific information about recent updates in Appendix VII, as usual, as well as notes two programs in Appendix IV — the Medicaid Cluster and the Abandoned Mine Land Reclamation program — that have been deemed “higher risk” programs.
In announcing the 2025 supplement, OMB also is enabling interested parties an opportunity to comment on the 2025 Supplement “to inform sound decisionmaking regarding guidance provided through the 2026 Compliance Supplement.” Although the Compliance Supplement is written for auditors to test compliance, we recommend grant recipients read the document so that they will be aware of what their auditors will be testing, which can result in a smoother audit all around.
To assist the audit community in preparing for testing financial assistance programs, OMB in August issued a draft version of the supplement to key audit stakeholders, however this version could not be completely relied upon until the final version was released. Auditors now can use the final version to complete their audits for submission to the Federal Audit Clearinghouse. Thompson Grants is currently reviewing the final supplement and will provide more information and analysis on the document next week.
Join us for our following Thompson Grants event:
2025 Thompson Grants Workshop: Subrecipient Monitoring | Dec. 9, 2025 | Virtual Event
