Delay On Uniform Guidance Information

As of the date of this notice, OMB has not released the final version. OMB issued a draft on August 18, 2025, but auditors may only utilize it for planning purposes. Auditors cannot submit Single Audit reports until the final supplement is published. The Federal government shutdown will likely extend the delay.  

It means your agency will complete and submit the financial statement audit independently of the Federal Single Audit. The Federal Single Audit will be finalized and submitted once OMB publishes the final 2025 Compliance Supplement.

The OSA is separating these audits to help ensure that critical financial information, audit opinions, and findings affecting public funds and entities in New Mexico are completed and published on time.

Waiting for the delayed Federal Single Audit guidance would unnecessarily postpone the release of important financial data reported in annual financial audits. By allowing agencies to submit financial audits separately, OSA ensures that the public, agency leadership, and lawmakers can act on accurate financial information without further delay.

It depends on how much your agency spends in federal awards during the fiscal year and when those awards were issued.

• If your agency expends $1,000,000 or more in federal awards issued on or after October 1, 2024, then you must undergo a Single Audit for fiscal years ending on or after September 30, 2025.
• If your agency’s federal awards were issued before October 1, 2024, the previous threshold of $750,000 still applies.

So, check both the issue date of your awards and your total federal expenditures for the fiscal year to determine if a Single Audit is required under 2 CFR §200.501 of the Uniform Guidance.

Due to the delayed release of the final 2025 Uniform Guidance Compliance Supplement by OMB, agencies requiring a Federal Single Audit cannot finalize that portion of their audit. To avoid delaying the completion of the financial statement audit, OSA is instructing affected agencies to amend their contracts to separate the financial statement audit from the Federal Single Audit.

Agencies must amend their contract by the due date specified for your agency type in the table below:  

Separating the audits may result in additional administrative effort or cost, depending on your agency’s circumstances and the terms negotiated with your IPA. For example, separating audits entails separate Management Representation Letters for each report, two exit conferences, and updated report language, among other considerations. Agencies are encouraged to discuss these implications early and directly with their auditors.

This should be a rare occurrence, but if this is your situation, please contact our office immediately for potential solutions.

The “one cover” requirement under NMAC 2.2.2.10(T)(4) mandates that the financial statement audit and Federal Single Audit be submitted as a single, unified report. OSA is temporarily waiving this requirement to allow agencies to submit the financial statement audit separately.

No. Agencies affected by the delay and this instruction do not need to request an exception to the Audit Rule regarding the due date. However, a late audit finding is permitted, if in the IPA’s professional judgment, the audit is late due to factors unrelated to the Uniform Guidance delay.

The draft Financial Audit report is due to OSA no later than the due date specified for your agency type in the table below:

OSA will determine the due date for all separate Singel Audits once OMB releases the Final Uniform Guidance Compliance Supplement.

The draft report must be submitted 15 days prior to the extended deadline for the primary agency. For example, if a county elects to submit its financial audit report by January 20, 2026, a component unit of that county—such as a hospital or housing authority—with a different IPA must submit its draft report to the OSA by January 5, 2026.

No. Once a contract is amended, it initiates manual processes that are complex and not easily reversible. Therefore, reverting to the “one-cover” approach is not permitted

Yes, but only for the single audit portion. For the first report, you may continue using the original guide. In sections where updates are expected, you can reference the forthcoming second report, which will be published at a later date.

1. Report Title “Department of Health Financial Statement Audit”
2. The Independent Auditor’s Report “in-relation-to” paragraph will exclude the SEFA and any other federal UG schedule.
3. The report will include a schedule of findings and responses containing all Financial Statement and findings required by NMSA 1978 12-6-5.
4. The agency will include an OSA-required  note disclosure about the change.  The language for this note disclosure has been provided to all IPAs.

All other requirements for the annual financial audit report will remain in effect.

1. Report Title: “Department of Health Single Audit.”
2. Table of contents.
3. Official Roster.
4. Uniform Guidance Report (this will have 2^nd report date) and require a specific paragraph with the in-relation to opinion on the SEFA.
5. SEFA that includes the reconciliation back to the FS (and any other UG related schedule such as HUD Statement and Certification of Actual Costs)
6. Notes to the SEFA
7. Schedule of findings and questioned costs
8. Financial statement findings
9. Uniform Guidance findings
10. Corrective Action Plan
11. Exit Conference
12. A separate MRL with this report date is required to be submitted to the OSA with the draft, essentially for the SEFA

For contracting questions please contact Bernadet Martinez at Bernadet.Martinez@osa.nm.gov or for technical assistance email the IT Helpdesk at helpdesk@osa.nm.gov.

For questions regarding reporting please contact Elise Mignardot Elise.Mignardot@osa.nm.gov or Donna Trujillo at DonnaM.Trujillo@osa.nm.gov.

• Proactively communicate with your agency’s IPA about this situation.

• Amend your contract with your IPA in accordance with OSA’s instructions to reflect the separation of the annual financial statement audit and Federal Single Audit.
• Prepare your Schedule of Expenditures of Federal Awards (SEFA).
• Organize documentation for both the financial statement audit and the Federal Single Audit.
• Stay informed by monitoring updates from OSA and OMB.