2025 OMB Compliance Supplement released

• Appendix IV (PDF - 812 KB), “Higher Risk Designation,” identifies programs that are designated as “higher risk” and includes guidance on how the “higher risk” designation impacts the major program determination process. All COVID-19-related programs were removed from the list in the 2025 Supplement, leaving only two programs that continue to be designated as “higher risk.”
• Appendix V (PDF - 812 KB), “List of Changes for the 2025 Compliance Supplement,” identifies changes that could affect single audit engagements. These changes apply across many of the programs in the 2025 Supplement that affect the scope of the single audit.
• Appendix VII (PDF - 812 KB), “Other Audit Advisories,” provides information on the latest OMB announcements that may impact 2025 single audits, including
  • The continuation of the requirement for recipients of federal awards to separately identify COVID-19-related expenditures from non-COVID-19 expenditures on the Schedule of Expenditures of Federal Awards (SEFA)
  • Guidance on determining whether an auditee’s prior-year Data Collection Form was submitted to the Federal Audit Clearinghouse on time for purposes of meeting the low-risk auditee criteria in the current year
  • A new section on the 2024 revisions to the OMB’s Guidance for Federal Financial Assistance, which includes updates to the Uniform Guidance, that discusses effective date considerations
• Part 3 (PDF - 1.7 MB), “Compliance Requirements,” is separated into Part 3.1 and Part 3.2, which reflect different requirements depending on whether federal agencies have implemented the 2024 revisions to the OMB’s Guidance for Federal Financial Assistance and the Uniform Guidance.
• The Student Financial Assistance cluster revises several compliance requirements, including several requirements in the Eligibility sections, Cash Management, and Special Tests and Provisions.

Other reminders

The terminology change from “Catalog of Federal Domestic Assistance” (CFDA) to “Assistance Listing” (AL) announced in the 2021 Compliance Supplement continues in the 2025 Supplement. The reference to AL is also reflected on the SEFA and the Data Collection Form. The AL is located at www.sam.gov.