OMB Clearance Supporting Statement PDF September 2010

8/31/10

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National Endowment for the Arts Supporting Statement
Blanket Justification for NEA Funding Application Guidelines and Reporting
Requirements
A. Justification
1. Explain the circumstances that make the collection of information necessary.
Identify any legal or administrative requirements that necessitate the
collection. Attach a copy of the appropriate section of each statute and
regulation mandating or authorizing the collection of information.
The Chairman of the National Endowment for the Arts is authorized to carry out a
program of grants-in-aid by the agency’s enabling legislation (20 U.S.C. §954). With
the recommendations of advisory panelists and members of the National Council on
the Arts, the Chairman establishes eligibility requirements and criteria for the review
of applications. Awards are made to nonprofit organizations, government agencies,
and individuals.
The Arts Endowment has limited federal funds and cannot fund all of the qualified
requests that it receives. Competitive review of applications for financial assistance
is performed by advisory panelists and the National Council on the Arts (composed
of 14 presidentially-appointed members and six members of Congress who serve ex
officio). The Council sends forward to the Chairman of the Arts Endowment those
applications that it recommends for funding. The Arts Endowment Chairman reviews
the Council’s recommendations and makes the final decision on all awards. The
information that is collected on the application form and accompanying
supplemental materials is used in the review process. This information is necessary
for the accurate, fair, and thorough consideration of competing proposals.
Recipients of federal funds are required to report on project activities and
expenditures. This is necessary to ensure that the federal funds are expended in
accordance with the terms and conditions of the grant award.

2. Indicate how, by whom, and for what purpose the information is to be used.
Except for a new collection, indicate the actual use the agency has made of
the information received from the current collection.
NEA staff sends completed application forms and other information requested in
response to the application guidelines to the advisory panelists for the appropriate
discipline/field in advance of each panel meeting. Each panel comprises a diverse
group of arts experts and other individuals including at least one knowledgeable
layperson. Panel membership rotates regularly.
The application guidelines ensure that all applicants submit comparable information.
Without the specific instructions provided by the guidelines, applications would vary

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in length, format, and consistency and the job of reviewing them would be
unmanageable. If this information was not collected (or not collected in a
standardized manner), panelists, the National Council, and the Arts Endowment’s
Chairman would not have the basis on which to make sound evaluations and
recommendations. Arbitrary or random methods would be required to select
applications for funding. The information that is being collected during the current
fiscal year will be the basis for next year’s awards and rejections.
Information that is collected on the application forms also is used for breakdowns of
our applications and grants -- for example, by budget size, by arts discipline, by type
of organization, etc. -- and for assessing the agency’s performance in carrying out
its goals.
Reports are required in order to ascertain that funded projects are proceeding with
and/or have been completed according to all of the terms and conditions of the
federal grant.

3. Describe whether, and to what extent, the collection of information involves
the use of automated, electronic, mechanical, or other technological collection
techniques or other forms of information technology, e.g., permitting
electronic submission of responses, and the basis for the decision for
adopting this means of collection. Also describe any consideration of using
information technology to reduce burden.
The Arts Endowment makes all of its application guidelines available on its Web site
and places application packages for all of its funding categories on Grants.gov. The
NEA’s guidelines provide direct links to the application packages on Grants.gov for
easy maneuverability. All applicants are required to submit their applications
electronically through Grants.gov. [Waivers are extremely limited, available only to
those who do not have internet access available within 30 miles of their
organization's business office or in cases where disability prevents the submission
of an electronic application.]
The agency also posts all of the instructions and forms for its reporting requirements
on its Web site. Final Descriptive and Final Status Reports may be faxed to the
agency. Literature Fellowship recipients can submit their final reports electronically.
Staff continues to explore ways of making the reporting function more fully
electronic.
The Arts Endowment has been heavily involved with Grants.gov, GMLOB, and other
government-wide streamlining efforts, and has a team of staff members that works
on these interagency efforts. The NEA has introduced and refined its electronic
application and reporting systems in response both to the government-wide
initiatives and to the agency’s desire to improve efficiency and the reliability and
usefulness of the information collected. In late 2009, the NEA contracted with an

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independent consulting group to conduct research on ways that the agency could
increase its use of technology in the grant application and review process. We will
continue to explore ways to refine our information technology systems for the benefit
of applicants, grantees, and staff.

4. Describe efforts to identify duplication. Show specifically why any similar
information already available cannot be used or modified for use for the
purposes described in Item 2 above.
The Arts Endowment uses standard Grants.gov forms for all of its electronic
applications: SF-424 Mandatory for government agencies; SF-424-Short for
nonprofit organizations; SF- 424-Individual for individuals, and the
Project/Performance Site Location Form for government agencies and nonprofit
organizations. (The NEA, working with the other cultural agencies, was instrumental
in helping to create the SF-424 Short and Individual forms, which are available
government-wide.) The NEA has carefully analyzed its own additional forms to make
certain that there is no duplication with the information requested by the Grants.gov
forms. We also have examined our own family of forms to see where consolidation
and uniformity was possible. The result is that we now have three basic sets of
forms, one for each of our major constituency types: government agencies (notably
the state arts agencies), nonprofit organizations, and individuals.
The Grants.gov and the NEA forms, together with other required supplementary
material, request the information that the agency needs to assess fairly applications
for financial assistance. Each year, most applicants apply for a single, specific
project. This project changes from year to year, as do the personnel involved and
the project budget. Much of the information collected one year is not relevant to the
next year’s request.
The reports on projects funded require specific information about federally funded
activities that were carried out during the project period. Again, information from
previous years is not current and is largely irrelevant.
In the case of government agencies, the Arts Endowment has a continuing
relationship with the state arts agencies and their regional arts organizations and
reviews plans from these agencies that cover all aspects of their programming. Full
proposals normally are reviewed only once every three years; only brief updates are
requested in the “out” years.
Each set of application guidelines is reviewed regularly by a wide variety of
representatives from the field. Some of the individuals involved have been
responsible for completing applications in the past. Others, as panel members, have
taken part in the application review process. These individuals are well qualified to
help assure that only essential information is requested and that it is as nonduplicative as possible.

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5. If the collection of information impacts small businesses or other small
entities, describe any methods used to minimize burden.
Some of the NEA’s funding opportunities are aimed specifically at sections of the
country, areas of cities, and rural areas that are not fully participating in the arts
experiences that are available in our nation. Particularly with these initiatives, special
attention has been given to minimizing the burden on applicants. In addition, all of
our application materials and reporting requirements are developed with sensitivity
to the constraints faced by small, independently-run, non-profit organizations.

6. Describe the consequence to federal program or policy activities if the
collection is not conducted or is conducted less frequently, as well as any
technical or legal obstacles to reducing burden.
The collection of information correlates directly with specific application deadlines
that are listed in the guidelines. Most applicants are limited to submitting a single
application, for a specific project, each year. The project for which they apply
changes from year to year.
Panelists review applications on their merits and in competition with other
applications in the same category. A grant awarded one year does not imply Arts
Endowment support in subsequent years. If the requested information was collected
less frequently, panelists would not have timely or accurate information on which to
base their evaluations. The Arts Endowment would be unable to ensure the fair and
accountable use of federal funds and would not be able to carry out its legislative
mandate.
Both OMB Circulars A-102 and A-110, as well as the Arts Endowment’s enabling
legislation (as amended), require the collection of reports from grant recipients.
Without these reports, the agency would not be able to determine whether funded
activities had been conducted according to the terms and conditions of the federal
grant. The application guidelines also state that acceptable reports must be received
by the report due dates in order for previous grantees to maintain eligibility for future
awards.
As noted in # 4 above, government agency proposals are on a three-year review
cycle.

7. Explain any special circumstances that would cause an information collection
to be conducted in a manner:
requiring respondents to report information to the agency more often than
quarterly;

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requiring respondents to prepare a written response to a collection of
information in fewer than 30 days after receipt of it;
requiring respondents to submit more than an original and two copies of
any document;
requiring respondents to retain records, other than health, medical,
government contract, grant-in-aid, or tax records, for more than three
years;
in connection with a statistical survey, that is not designed to produce
valid and reliable results that can be generalized to the universe of study;
requiring the use of a statistical data classification that has not been
reviewed and approved by OMB;
that includes a pledge of confidentiality that is not supported by authority
established in statue or regulation, that is not supported by disclosure and
data security policies that are consistent with the pledge, or which
unnecessarily impedes sharing of data with other agencies for compatible
confidential use; or
requiring respondents to submit proprietary trade secrets, or other
confidential information unless the agency can demonstrate that it has
instituted procedures to protect the information’s confidentiality to the
extent permitted by law.
The agency intends to collect the vast majority of its information from applicants in a
manner that does not necessitate any of the special requirements noted above.
However, there are limited instances where the Chairman, as provided for in our
legislation, may want to respond quickly to a specific need or opportunity in the field,
particularly when this can help the NEA fulfill its goal of providing grants in areas
that are underserved. In such cases, an applicant may be asked to respond to a
collection of information in fewer than 30 days. A short turn-around time at the
application stage would be part of an expedited review and processing cycle
designed to benefit the respondent.

8. If applicable, provide a copy and identify the date and page number of
publication in the Federal Register of the agency’s notice, required by 5 CFR
1320.8 (d), soliciting comments on the information collection prior to
submission to OMB. Summarize public comments received in response to that
notice and describe actions taken by the agency in response to these
comments. Specifically address comments received on cost and hour burden.
Describe efforts to consult with persons outside the agency to obtain their
views on the availability of data, frequency of collection, the clarity of
instructions and recordkeeping, disclosure, or reporting format (if any), and
on the data elements to be recorded, disclosed, or reported.

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Consultation with representatives of those from whom information is to be
obtained or those who must compile records should occur at least once every
3 years--even if the collection of information activity is the same as in prior
periods. There may be circumstances that may preclude consultation in a
specific situation. These circumstances should be explained.
A notice was published in the Federal Register (document 2010-16155) on July 2,
2010, to solicit comments on the “Blanket Justification for NEA Funding Application
Guidelines and Reporting Requirements” prior to submission of this OMB clearance
request. No public comments were received at the NEA in response to this notice.
The Arts Endowment’s advisory panels meet throughout the year to review
applications, to help develop or revise application guidelines, and to discuss
program policy. Panels discuss the application guidelines and suggest
improvements to them. Panel members are consulted regularly as to the clarity of
the application guidelines and the value of the information that is requested. The
National Council on the Arts devotes a portion of its meeting time to a discussion of
the application guidelines.
Arts Endowment staff members also consult regularly with individuals in their fields
including at meetings and while traveling outside of Washington, DC. Service
organizations and state arts agencies sometimes provide suggestions on the
application guidelines from their constituents. The staff also receives and considers
unsolicited suggestions for revising the application guidelines from interested
individuals and organizations in the field.

9. Explain any decision to provide any payment or gift to respondents, other than
reenumeration of contractors or grantees.
Not applicable. The Arts Endowment does not provide any payments or gifts to
respondents.

10. Describe any assurance of confidentiality provided to respondents and the
basis for the assurance in statute, regulation, or agency policy.
Assurance of confidentiality is provided under the terms of the Privacy Act of 1974.
The Arts Endowment is authorized to solicit applicant information by the agency’s
enabling legislation [20 U.S.C. §954].

11. Provide additional justification for any questions of a sensitive nature, such as
sexual behavior and attitudes, religious beliefs, and other matters that are
commonly considered private. This justification should include the reasons
why the agency considers the questions necessary, the specific uses to be

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made of the information, the explanation to be given to persons from whom
the information is requested, and any steps to be taken to obtain their
consent.
No questions of a sensitive nature are included in the information collection.

12. Provide estimates of the hour burden of the collection of information. The
statement should:
Indicate the number of respondents, frequency of response, annual hour
burden, and an explanation of how the burden was estimated. Unless
directed to do so, agencies should not conduct special surveys to obtain
information on which to base hour burden estimates. Consultation with a
sample (fewer than 10) of potential respondents is desirable. If the hour
burden on respondents is expected to vary widely because of differences
in activity, size, or complexity, show the range of estimated hour burden,
and explain the reasons for the variance. Generally, estimates should not
include burden hours for customary and usual business practices.
If this request for approval covers more than one form, provide separate
hour burden estimates for each form and aggregate the hour burdens.
Provide estimates of annualized cost to respondents for the hour burdens
for collections of information, identifying and using appropriate wage rate
categories. The cost of contracting out or paying outside parties for
information collection activities should not be included here. Instead, this
cost should be included in Item 14.

7

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ESTIMATED BURDEN (IN HOURS) FOR APPLICATIONS AND FOR REPORTING
The chart below is broken out by the three basic types of recipients, which correspond
to the three basic sets of forms/supplementary material that the NEA requests of its
applicants. Figures are based on a frequency of one response per year for applications
and one for reporting.
Type of
Recipient

Est. #
of
Apps

Nonprofit
4,500
Orgs
Gov
64*
Agencies
Individuals 1,150
TOTALS

5,714

Average
Time
per App

Est.
Reporting
Burden for
Applications
(Hours)

Est. #
of
Grant
Reports

Average
Time per
Report

Est. Reporting
Burden for Grant
Reports (Hours)

29

130,500

2,500

8

20,000

15

960

64

8

512

11.83

13,605

75

1

75

145,065

2,639

20,587

*Includes both full and off-year requests.

The application guidelines burden is estimated at 145,065 hours. This burden is
calculated by multiplying the estimated number of applications for each type of
applicant x the estimated average hourly response burden for that type x 1 response
per year. The category totals are added together for an agency-wide estimate of
145,065. With an agency-wide estimate of 5,714 applications, this works out to an
agency average of 25.4 hours per response.
This average hours-per-response differs significantly by applicant type: from 29
hours for nonprofit organizations to 11.8 hours for individuals. The average for
government agencies is 15 hours, but this figure includes both the state arts
agencies and regional organizations that are submitting full proposals (due every
three years and estimated at 31.4 hours per proposal) and those other more
numerous agencies that are submitting only off-year updates (estimated at just
under 8 hours per response).
There is also some variation within the nonprofit organizations group. The estimated
application burden for most of these applicants is 31.5 hours. However, certain
categories of funding are designed specifically to increase access in underserved
areas and have simplified application requirements; the time burden for these
categories is estimated at 9.5 hours.
The reporting requirements burden is estimated at 20,587 hours. This burden is
calculated by multiplying the estimated number of grants for each type of recipient x

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the estimated hourly response burden for that type x 1 response per year. The
category totals are added together for an agency-wide estimate of 20,587 hours.
With an agency-wide estimate of 2,639 grantees, this works out to an agency
average of 7.8 hours per response. This agency-wide average includes both
organizations (nonprofits and government agencies) whose reporting burden is
estimated at 8 hours each and individuals where the estimate is 1 hour per grantee.
The total annual burden (application guidelines burden and reporting requirements
burden) is estimated at 165,652 hours. (The ICR reports the total annual burden
estimate at 165,637; slight differences are due to rounding.)

COST TO RESPONDENTS/APPLICATIONS
Type of
Recipient

Est. # of
Apps

Average # of
Hours per
Application

Total Hours

Average
Hourly
Wage

Total

Nonprofit Orgs

4,500

29

130,500

$21

$2,740,500

Gov Agencies

64*

15

960

$23

$22,080

Individuals

1,150

11.83

13,605

$23

TOTALS

5,714

$312,915
$3,075,495

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COST TO RESPONDENTS/REPORTING
Type of
Recipient

Est. # of
Grants

Average # of
Hours per
Grant
Report

Total Hours

Nonprofit Orgs

2,500

8

20,000

$21

$420,000

Gov Agencies

64*

8

512

$20.30

$10,394

Individuals

75

1

75

$23

$1,725

TOTALS

2,639

Average
Hourly
Wage

Total

$432,119

TOTAL COST TO RESPONDENTS = $3,507,614
The total estimated burden to applicants and grantees combined is $3,507,614
($3,075,495 for applications and $432,119 for reporting). The figures above were
estimated as follows. NEA staff was consulted as to the division of respondent time
between professional staff and support staff for each type of recipient for both
applications and reports. The average hourly wage was computed factoring in
professional and support staff wages proportionate to the amount of time each
typically spends preparing applications and reports. Salaries for personnel at
nonprofit organizations and government agencies were estimated based on 1)
salaries provided in this submission three years ago adjusted for Cost of Living
Adjustments for the past three years; 2) a sampling of salaries presented in current
applications; and 3) consultation with NEA staff. Salaries for individuals were
estimated based on 1) 2010 average salaries for assistant professors and
instructors at colleges and universities; and 2) consultation with NEA staff.

13. Provide an estimate of the total annual cost burden to respondents or
recordkeepers resulting from the collection of information. (Do not include the
cost of any hour burden already reflected on the burden worksheet.)
The cost estimate should be split into two components: (a) a total capital
and start-up cost component (annualized over its expected useful life) and
(b) a total operation and maintenance and purchase of services
component. The estimates should take into account costs associated with
generating, maintaining, and disclosing or providing the information.
Include descriptions of methods used to estimate major cost factors
including system and technology acquisition, expected useful life of capital
equipment, the discount rate(s), and the time period over which costs will
be incurred. Capital and start-up costs include, among other items,
preparations for collecting information such as purchasing computers and

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software; monitoring, sampling, drilling and testing equipment; and record
storage facilities.
If cost estimates are expected to vary widely, agencies should present
ranges of cost burdens and explain the reasons for the variance. The cost
of purchasing or contracting out information collection services should be
a part of this cost burden estimate. In developing cost burden estimates,
agencies may consult with a sample of respondents (fewer than 10), utilize
the 60-day pre-OMB submission public comment process and use existing
economic or regulatory impact analysis associated with the rulemaking
containing the information collection, as appropriate.
Generally, estimates should not include purchases of equipment or
services, or portions thereof, made: (1) prior to October 1, 1995, (2) to
achieve regulatory compliance with requirements not associated with the
information collection, (3) for reasons other than to provide information or
keep records for the government, or (4) as part of customary and usual
business or private practices.
Not applicable. There are no annual costs to respondents or recordkeepers resulting
from this collection of information.

14. Provide estimates of annualized cost to the federal government. Also, provide
a description of the method used to estimate cost, which should include
quantification of hours, operational expenses (such as equipment, printing,
and support staff), and any other expense that would not have been incurred
without this collection of information. Agencies may also aggregate cost
estimates from Items 12, 13, and 14 in a single table.
COST TO FEDERAL GOVERNMENT
NEA Application/Report Review

Type of Review

Applications
Reports
TOTAL

Est. #

5,714
2,639

Average # of
Hours per
Application
or Report

Total Hours

8
1

45,712
2,639

Average
Hourly
Wage

$46.14
$51.13

Total

$2,109,152
$134,932
$2,244,084

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TOTAL COST TO FEDERAL GOVERNMENT

12

= $2,244,084

In the chart above, the estimated number of hours for staff review of applications
and reports is based on staff experience with these tasks over a number of years.
The Average Hourly Wages were developed in consultation with agency staff, based
on the following. The review of applications averages 8 hours each. Each 8 hour
review involves: 4 hours for the Discipline Specialist (average wage at the GS 12/5
level); 3 hours for Support Staff (average wage GS 7/2); and 1 hour for the Program
Director (average wage GS 15/6). We computed the pay of these 3 positions (using
the Office of Personnel Management Salary Tables for the D.C. area)
proportionately to the time spent by each, to come up with an average hourly rate of
$37. To this, we added 24.7% fringe benefits for a total of $46.14. The review of
reports averages 1 hour per report, with this time evenly split between a Final
Reports Officer and a Discipline Specialist (both estimated at GS 12/Step 5). The
pay here, coupled with a 24.7% fringe benefits rate, provides an estimated hourly
rate of $51.13.

15. Explain the reasons for any program changes or adjustments reported on the
burden worksheet.
The Arts Endowment remains committed to supporting the arts in communities –
large and small, urban and rural– throughout the country, and continues to engage
in outreach activities to connect with underserved areas. In addition, the posting of
our guidelines on the agency’s Web site and our application packages on
Grants.gov has increased awareness of and access to our grant opportunities for
organizations and individuals throughout the country. The current state of the U.S.
economy, and the greater visibility and attention focused on the Arts Endowment
because of its participation in the American Recovery and Reinvestment Act, have
also contributed to an increase in applications.
While we have attempted to expand our reach, we also regularly examine our grant
opportunities to see where consolidation might be desirable. The NEA has been
engaged in a major strategic planning effort and has been examining all of its grant
categories and initiatives carefully as part of this activity. The agency's strategic
planning has also led to a sharper focus on goals, outcomes, and measures, and we
are asking both applicants and grantees to address these items more closely.
Based on current trends and projections, our overall estimated number of
applications has increased, from 5,345 in our last submission three years ago, to a
current estimate of 5,714. Our projected number of grants, and therefore reports,
also shows a modest increase from estimates of three years ago: from 2,228 to
2,639.

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With the projected increase in the numbers of applications and grants, our hourly
burden estimates are also up. Increases in cost burden, both for respondents and
the federal government, reflect both the larger number of applications and grants
anticipated and cost of living increases from three-years ago.

16. For collections of information whose results will be published, outline plans
for tabulation and publication. Address any complex analytical techniques that
will be used. Provide the time schedule for the entire project, including
beginning and ending dates of the collection of information, completion of
report, publication dates, and other actions.
Not applicable.

17. If seeking approval to not display the expiration date for OMB approval of the
information collection, explain the reasons that display would be
inappropriate.
Displaying the expiration date for OMB approval of the information collection is
appropriate. The expiration date will be displayed on all application guidelines
(including each form) and reporting requirements.

18. Explain each exception to the certification statement identified in
“Certification for Paperwork Reduction Act Submissions.”
Not applicable. There are no exceptions to the certification statement.

B. Collections of Information Employing Statistical Methods
Not applicable. This collection of information does not employ statistical methods.