FDR Supporting Statement 2018

9/11/2018
National Endowment for the Arts Supporting Statement
NEA Funding Reporting Requirements - Final Descriptive Reports FY2019 and
Later
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 (see ICR Reference No: 201608-3135-001 / OMB Control #31350112). Awards are made to nonprofit organizations, government agencies, and
individuals.
Final Descriptive Reports (FDR) elicit relevant information from individuals, nonprofit
organizations, and government arts agencies that receive funding from the National
Endowment for the Arts (see ICR Reference No: 201608-3135-001 / OMB Control
#3135-0112 for more detail on these programs). According to OMB 2 CFR part 200,
recipients of federal funds are required to report on project activities and
expenditures. Reporting requirements are necessary to ascertain that grant projects
have been completed, and that all terms and conditions have been fulfilled.
The National Endowment for the Arts also collects information regarding the location
of project activity to understand the geographic scope and distribution of NEAapproved grant and cooperative agreement activities. This is collected through the
Geographic Location of Project Activity (or GEO) portion of the Final Report. This
information is used in our reports to Congress, the federal Office of Management
and Budget, and the public.
Previously, these FDRs were included in the Blanket Justification for NEA Funding
Application Guidelines and Reporting Requirements for Government Agencies (see
ICR Reference No: 201608-3135-001 / OMB Control #3135-0112). However, due to
changes in the FDR narrative questions and the GEO form, we are submitting the
FDRs for clearance separate from the Application Guidelines.

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.

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Final Descriptive Reports are required to be submitted by grantees 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. The submitted forms
are reviewed for compliance by the NEA Grants & Contracts Office staff and then
turned over to the respective discipline offices.
The Office of Research and Analysis uses FDR data for analysis and evaluation of
grant programs. Findings from analysis of FDR data are also used in the Annual
Performance Report, which is submitted to OMB and Congress.
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.
Beginning with grants made in the Fiscal Year 2012 award cycle, Final Descriptive
Reports must be submitted to the agency electronically. The National Endowment
for the Arts posts all of the instructions and forms for its reporting requirements on its
website, under the Manage Your Award tab. Final Descriptive Reports are fillable
PDF forms submitted through NEA’s new online awards management system,
REACH. For the GEO portion of the Final Report, grantees must complete the online
form, list their significant project activity locations in the accompanying excel
spreadsheet template, and submit it through the NEA website.
The National Endowment for the Arts has refined its electronic reporting systems in
response to government-wide initiatives (such as the President's Open Data Policy)
and to the agency’s desire to improve efficiency and the reliability and usefulness of
the information collected. This has created efficiencies for staff by electronically
validating what is submitted, as well as providing us with easy access to information
in data fields for dissemination, decision-making, and research purposes. 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 reports on projects funded require specific information about federally funded
activities that were carried out during the project period. Each year, most applicants
apply and report on 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.

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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 National Endowment for the Arts’ funding opportunities and subsequent
awards 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. All of our 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.
Both OMB 2 CFR Part 200 and the National Endowment for the Arts’ 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.

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;
• 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

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instituted procedures to protect the information’s confidentiality to the
extent permitted by law.
The agency intends to collect its information from grantees in a manner that does
not necessitate any of the special requirements noted above.
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.
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, Vol. 83, 30195 (document 201813777) on June 27, 2018, to solicit comments on the “Final Descriptive Reports for
Recipients of the National Endowment for the Arts Grant Awards” prior to
submission of this OMB clearance request. One public comment was received and
taken into consideration at the National Endowment for the Arts in response to this
notice.
National Endowment for the Arts staff members also consult regularly with
individuals in their fields nationwide. Service organizations and state arts agencies
sometimes provide suggestions on report forms and requirements from their
constituents. The Our Town report was designed following the development in 2017
of a theory of change and logic model through consultation with external subject
matter experts.

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

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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 National Endowment for the Arts 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
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.
ESTIMATED BURDEN (IN HOURS) 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 National
Endowment for the Arts requests of its applicants. Figures are based on a frequency
of one response per year for reporting.

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Est. # of Grant
Reports

Type of Recipient

Average Time
per Report

Est. Reporting Burden
for Grant Reports
(Hours)

Nonprofit Orgs

2,369

10

23,690

Gov Agencies

64

8

512

Individuals
Totals

74

0.5

37

2,507

24,239

The total reporting requirements burden is estimated at 24,239 hours. This burden is
calculated by multiplying the estimated number of grants for each type of recipient x
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 24,239 hours.
With an agency-wide estimate of 2,507 grantees, this works out to an agency
average of 10 hours per response. This agency-wide average includes both
organizations (nonprofits and government agencies) whose reporting burden is
estimated at 10 hours each and individuals where the estimate is 0.5 hour per
grantee.

COST TO RESPONDENTS/REPORTING
Type of
Recipient

Nonprofit
Orgs
Gov
Agencies
Individuals
TOTALS

Est. # of
Grants

Average # of
Hours per
Grant Report

Total Hours

Average
Hourly
Wage

Total

2,369

10

23,690

$23

$544,870

64

8

512

$21.75

$11,136

74

0.5

37

$31

$1,147

2,507

$557,153

TOTAL COST TO RESPONDENTS = $557,153
The total estimated burden to grantees is $557,153. The figures above were
estimated using figures from previous submission as follows. The National
Endowment for the Arts staff was consulted as to the division of respondent time
between professional staff and support staff for each type of recipient. The average
hourly wage was computed factoring in professional and support staff wages
proportionate to the amount of time each typically spends preparing reports. Salaries
for personnel at nonprofit organizations and government agencies were estimated
based on 1) salaries provided in this submission two years ago adjusted for Cost of

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Living Adjustments for the past three years; 2) a sampling of salaries presented in
current applications; and 3) consultation with National Endowment for the Arts staff.
Salaries for individuals were estimated based on 1) 2016 average salaries for
assistant professors and instructors at colleges and universities; and 2) consultation
with National Endowment for the Arts 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
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 record keepers
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.

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COST TO FEDERAL GOVERNMENT
NEA Application/Report Review
Type of
Review

Reports

Est. #
Grants

2,507

Average # of
Hours per
Application or
Report

2

Total
Hours

5,014

Average
Hourly
Wage

$60.21

Total

$301,893

COST TO FEDERAL GOVERNMENT = $301,893
In the chart above, the estimated number of hours for staff review of 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 reports averages 2 hour per report by a Final Reports Officer (average
wage GS 12/Step 10). The pay here, coupled with a 30.9% fringe benefits rate,
provides an estimated hourly rate of $60.21. The total cost to federal government is
calculated by estimated number of reports x average number of hours per report x
average hourly wage.
15. Explain the reasons for any program changes or adjustments reported on the
burden worksheet.
In previous years, Final Descriptive Reports were approved under OMB Control
#3135-0112. Based on the relevant burden hours from the previous OMB control
number, increases in cost burden, both for respondents and the federal government,
are due primarily to: increased numbers of grant awards; cost of living increases
over the three-year period; and additional reporting requirements associated with
OMB 2 CFR Part 200.
Based on current trends and projections, our overall estimated number of grants has
increased, from 2,368 in our last submission two years ago, to a current estimate of
2,507. This number represents an increase in application numbers from nonprofits
and from individuals.
The National Endowment for the Arts 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 website and a series of
guidelines webinars has increased awareness of and access to our grant
opportunities for organizations and individuals throughout the country.

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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.
The Final Descriptive Report include data pertaining to many of the agency’s
strategic objectives and utilized in drafting the agency’s Annual Performance Report.
The Government Performance and Results Act (GPRA) Modernization Act and the
Office of Management and Budget (OMB) require that agencies report on their
performance at the end of each fiscal year. The Annual Performance Report
provides information on the agency's progress achieving the goals and objectives
described in the agency’s Strategic Plan, including progress on strategic objectives,
performance goals and Agency Priority Goals.
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 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.