2025 Compliance Supplement Update

After a long delay, the 2025 Compliance Supplement was issued November 25, 2025 and is effective for audits for fiscal years beginning after June 30, 2024 (the fiscal year of July 1, 2024-June 30, 2025).

An ideal place to start when reviewing the 2025 Compliance Supplement is to refer to Appendix V (page 2,185) for a list of changes from the 2024 Compliance Supplement. There have been changes to many federal programs and clusters.  We encourage you to review the list of programs to determine if your organization has received funding from any of these modified programs. If you have any questions regarding changes to these programs, please do not hesitate to contact a member of your audit team.

Key Highlights and Updates

Part 3 of the 2025 Compliance Supplement is divided into Part 3.1 (the previous Uniform Guidance – the audit period before October 1, 2024) and Part 3.2 (the 2024 Uniform Guidance – the audit period on or after October 1, 2024 ). Your auditors will use the applicable time frame to test your awards, and they will make sure to correctly map each award to Part 3.1 (the former Uniform Guidance ) versus Part 3.2 (the 2024 Uniform Guidance).

Higher Risk Programs

The following programs are defined as “higher risk”:

• 93.778/93.777/93.775 – Medicaid Cluster
• 15.252 – Bipartisan Infrastructure Law (BIL) Abandoned Mine Land (AML) Grants

The following programs have been removed from the “higher risk” list:

• 21.023 – Emergency Rental Assistance
• 21.027 – Coronavirus State and Local Fiscal Recovery Funds

Single Audit Threshold and Timing

The new $1,000,000 audit and major program determination threshold applies to non-federal entities’ fiscal years beginning on or after October 1, 2024 (Fiscal Year End September 30, 2025 and later).

Single Audit Submission Due Date

The Single Audit submission due date is defined as the earlier of 9 months after the end of the audit period and 30 calendar days after the entity has received its audit report. You can compare the “FAC (Federal Audit Clearinghouse) Accepted Date” to the earlier of the 9 months and 30 days to determine if the due date has been met.

COVID-19 Expenditures

The 2025 Compliance Supplement has retained the additional requirements regarding COVID-19 expenditures in Appendix VII (refer to page 2,193). Listed below are some highlights you should be aware of:

• The requirement to separately identify COVID-19 expenditures on the SEFA (Schedule of Expenditures of Federal Awards) and Data Collection Form has been retained.
• For reporting on the SEFA, COVID-19 expenditures should be reported on a separate line by ALN (Assistance Listing Number) with “COVID-19” as a prefix to the program name.
• For reporting on the Data Collection Form, COVID-19 expenditures should be reported on a separate row with “COVID-19” in Part II Item 1C, Additional Award Identification.

If you have any questions regarding the updates to the 2025 Compliance Supplement and how these changes affect your audit, please contact a member of your audit team.