Understanding the Department’s New Audit Submission Requirements

By Kimberly Cravotta, FAAC® | April 8, 2024

In October 2023, the Department announced an amendment to § 668.23(a) to require that audit reports are timely submitted, by the earlier of 30 days after the completion of the report or six months after the end of the institution’s fiscal year. Furthermore, when the regulations go into effect on July 1, 2024, the federal register establishes the submission deadline for an institution to submit its compliance audit and audited financial statements as the earlier of six months after the last day of the institution’s fiscal year or 30 days after the date of the later auditor’s report. To clarify, if an institution’s compliance audit is issued first and the institution is then awaiting the financial statement audit, the submission “clock” will not start until the financial statement audit report has been issued as it is the later of in this situation. Once that final audit is issued, you have 30 days to submit your reports to the Department.

However, these new regulations are not effective until July 1, 2024, so they will not impact September 30, 2023 and December 31, 2023 year-end audits. At this time, the current or old audit submission deadline is still in place where an institution must submit annually to the Secretary its compliance audit and its audited financial statements no later than six months after the last day of the institution’s fiscal year.

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