Arts Endowment Supporting Statement A 2019 - Revised

9/3/2019, Revised 10/3/2019 to include Summary of Changes
National Endowment for the Arts Supporting Statement
Blanket Justification for Arts Endowment Funding Application Guidelines and
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 (“Arts Endowment”) 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 Arts Endowment Chairman
establishes eligibility requirements and criteria for the review of applications.
Applications for funding are accepted at different deadlines throughout the year for a
variety of arts projects from 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 (currently
composed of 17 Presidentially-appointed members and three members of Congress
who serve ex officio). The Council sends forward to the Arts Endowment Chairman
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 funding proposals.
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.
Arts Endowment staff post to an online application review system the completed
application forms and other information submitted by grant applicants so that
advisory panelists may review these materials. Each advisory 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
in length, format, and consistency and the job of reviewing them would be
untenable. If this information was not collected (or not collected in a standardized
manner), advisory panelists, the National Council on the Arts, and the Arts

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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.
Information that is collected on the application forms also is used for breakdowns of
our applications—for example, by arts discipline, by project type, by type of
organization, etc.—and for assessing the agency’s performance in carrying out its
objectives.
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 website
and places application packages for all of its funding categories on Grants.gov. The
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 and the Arts Endowment’s online Applicant Portal (for certain
funding categories only). Waivers are extremely limited, available only to those who
do not have internet access available within 30 miles of their address or in cases
where disability prevents the submission of an electronic application.
The Arts Endowment has greatly refined its electronic application systems in
response to government-wide initiatives and to the agency’s desire to improve
efficiency and the reliability and usefulness of the information collected. Most
applicants submit a majority of their applications via consolidated webforms located
on the agency’s Applicant Portal whenever possible. This has created efficiencies
for staff by electronically validating what is submitted, as well as providing easy
access to information in data fields for dissemination, decision-making, and
research purposes. Applicants have benefited from these efficiencies as well.
Instead of submitting multiple application forms as PDF attachments, they enter
information into one webform. We continually explore ways to refine our information
technology systems for the benefit of applicants, panelists, 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 Grants.gov’s standard Application for Federal Domestic
Assistance forms for all of its electronic applications: SF-424 Mandatory for
government agencies; SF-424-Short for nonprofit organizations; and the SF- 424Individual for individuals.

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We 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 Arts Endowment 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 Grants.gov and the Arts Endowment forms, together with other required
supplementary material, request the information that the agency needs to assess
consistently 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, timelines, and the project budget. Much of the information
collected one year is not relevant to the next year’s request since it is not current.
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 aspects of their programming. Full
proposals normally are reviewed only once every three years; only brief updates are
requested in the “off” years.
Each set of application guidelines is reviewed regularly by a wide variety of
representatives from the field. Many 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.
5. If the collection of information impacts small businesses or other small
entities, describe any methods used to minimize burden.
Some of the Arts Endowment’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 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.

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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.
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
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 Arts Endowment 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 Arts Endowment 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

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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. 84, No. 126 (document 201913955) on July 1, 2019, to solicit comments on the “Blanket Justification for Arts
Endowment Funding Application Guidelines and Requirements” prior to submission
of this OMB clearance request. No public comments were received at the Arts
Endowment in response to this notice.
Advisory panelists who review applications are regularly consulted as to the clarity of
the application guidelines and the value of the information that is requested. In
addition, 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
nationwide. Service organizations and state arts agencies often provide suggestions
on the application guidelines from their constituents. The staff also receive and
consider suggestions for revising the application guidelines from applicants through
an anonymous survey administered to a random sampling of applicants after each
of the agency’s principal grant deadlines.
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 for under the terms of the Privacy Act of
1974.

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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
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 RESPONDENT BURDEN (IN HOURS) FOR APPLICATIONS
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 Arts
Endowment requests of its applicants. Figures are based on a frequency of one
response per year for applications.
Type of
Recipient

Est. #
of
Apps

Average
Time
per App

Nonprofit
Orgs

4,500

25

Est. Reporting Burden for
Applications (Hours)

112,500

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Gov
Agencies

63*

14

882

Individuals

1,900

11

20,900

TOTALS

6,463

134,282

*Includes both full and off-year requests.

The total annual burden (in hours) of the application guidelines is estimated at
134,282 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 134,282 hours. With an agency-wide estimate of
6,463 applications, this works out to an agency average of 21 hours per response.
This average hours-per-response differs significantly by applicant type: from 25
hours for nonprofit organizations to 11 hours for individuals. The average for
government agencies is 14 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 hours per proposal) and those other more
numerous agencies that are submitting only off-year updates (estimated at 7 hours
per response).
There is also some variation within the nonprofit organizations group. The estimated
application burden for most of these applicants is 27 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 11 hours.
ESTIMATED RESPONDENT BURDEN (COST) FOR APPLICATIONS
Type of
Recipient

Est. # of
Apps

Average # of
Hours per
Application

Total Hours

Average
Hourly
Wage

Total

Nonprofit Orgs

4,500

25

112,500

$24

$2,700,000

Gov Agencies

63*

14

882

$26.40

$23,285

Individuals

1,900

11

20,900

$37

$773,300

TOTALS

6,463

$3,496,585

The total annual cost burden to applicants (in dollars) is $3,496,585. The figures
above were estimated as follows. Arts Endowment staff were 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

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preparing applications. 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 Arts Endowment staff. Salaries for individuals were estimated
based on 1) 2018-2019 average salaries for assistant professors and instructors at
U.S. colleges and universities; and 2) consultation with Arts Endowment 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 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

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without this collection of information. Agencies may also aggregate cost
estimates from Items 12, 13, and 14 in a single table.
ESTIMATED FEDERAL GOVERNMENT BURDEN FOR APPLICATIONS
Type of Review

Est. #

Average # of
Hours per
Application

Total Hours

Average
Hourly
Wage

Total

Applications
TOTAL

6,463

6

38,778

$63

$2,443,014
$2,443,014

The total estimated annual cost to the Federal Government is $2,443,014. In the
chart above, the estimated number of hours for staff review of applications is
based on staff experience with these tasks over a number of years. The Average
Hourly Wage was developed in consultation with agency staff, based on the
following. The review of applications averages 6 hours each. Each 6 hour review
involves: 4 hours for the Program Specialist (average wage at the GS 12/5 level); 1
hour for Support Staff (average wage GS 9/1); and 1 hour for the Program Director
(average wage GS 15/6). We computed the pay of these 3 positions (using the U.S.
Office of Personnel Management’s 2019 Salary Tables for the D.C. area)
proportionately to the time spent by each, to come up with an average hourly rate of
$63. This figure includes an estimated 30.9% fringe benefits rate.
15. Explain the reasons for any program changes or adjustments reported on the
burden worksheet.
When this information collection was last cleared three years ago (ICR Ref. No.
201608-3135-001), it included all of the Arts Endowment’s grantee final reporting
forms and instructions in addition to the agency’s application guidelines and
requirements. To better align with Arts Endowment’s 2018-2022 Strategic Plan,
grantee final reporting requirements have been cleared with OMB on a separate
schedule since 2018 (ICR Ref. No. 201809-3135-002). As a result, the overall
decrease in annual burden to respondents and the Federal Government is primarily
attributed to this submission’s focus on application guidelines and requirements
only.
With respect to the application guidelines and requirements, the federal
government’s burden for these costs has increased slightly since 2016 from
$2,264,717 to $2,443,014 due to Cost of Living Adjustments over the past three
years. Similarly, the cost to respondents for the same period of time has increased
from $3,382,573 to $3,496,585 due the same factors.
To mitigate the overall impact of these changes, we have carefully examined all of
our grant funding opportunities to see where streamlining and consolidation might
be desirable. Our efforts led us to simplify the application instructions and
requirements, improve the presentation of application materials on our website, and

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refine our application webforms. For example, the application guidelines and
requirements for nonprofit organizations (approximately 4,500 applications per year)
will see respondents’ average time spent per application reduced by one hour—
resulting in an estimated overall annual decrease of 6,580 hours from three years
ago.
The application instructions and requirements for only one area (Individuals) will see
a modest increase in annual applicant burden from three years ago. This is because
we have consolidated all of the agency’s application materials and requirements into
this submission, incorporating two forms for individuals that OMB has previously
approved.
A summary of changes to the Arts Endowment’s application guidelines and
requirements is included at the bottom of this document (see “2019 PRA Summary
of Changes” below).
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).
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.
_____________________________________________________________________

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2019 PRA Summary of Changes to Application Guidelines and Requirements:
Area

Potential Change

Notes

Continue to provide one data field only
for each year/season.

Overall decrease of
7,500 characters from
this year.

GAP=Grants for
Arts Projects
CA=Challenge
America
OT=Our Town
ORA=Research
Grants in the Arts,
Research Labs

APPLICATION
FORMS:
Arts
Programmatic
History
GAP, CA, OT

AND
Request audience numbers for
consecutive years programming, if
applicable (GAP only).
AND
Reduce character count per data field
from 3,500 to 1,000.

Project Title
GAP, CA, OT,
ORA
Project
Description
GAP, CA, OT

Major Project
Activities
GAP, CA

Applicants will enter a project title only
once (during Part 2).

Rename “Project Summary”
AND

Overall decrease of
250 characters from
this year.

Reduce character count from 1,000 to
750.
Rename “Project Description”
AND

Overall decrease of
1,000 characters from
this year.

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Reduce character count from 4,000 to
3,000.
Project Partners
Key Individuals
GAP, CA

Merge Project Partners and Key
Individuals into one section.
AND
Request titles for individuals.

Overall decrease of up
to 5 data fields from
this year; overall
increase of 2,500
characters.

AND
Allow for any combination of up to 10
partners/individuals. Each data field will
have 1,000 characters.
Promotion &
Publicity
Intended
Audience/
Participants/
Community
GAP
Performance
Measurement
GAP

Merge “Promotion & Publicity” with
“Intended Audience/Participants/
Community”.
AND
Allow for one data field with a 2,000
character limit.
Add reference to student assessment
and education standards for Arts
Education only.

Project Budget
Instructions

Add a data field to allow for optional
clarifying notes for budget line items.

GAP, CA, OT,
ORA
Special Items:
Literary Arts

750 character limit.

GAP
Organization &
Project Info
GAP, CA, OT

Overall decrease of
1,000 characters from
this year.

For magazines and presses, add
distributor’s name or a description of the
distribution plan
Add “Tribal Community” to Organization
Description to list of options.
AND

Increase of 750
characters from this
year.

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Add disaster preparedness plan question
(Y/N question).
AND
Add “Other racial/ethnic group” and “No
specific racial/ethnic group” to list of
group options.
AND
Add “No specific age group” to list of
options.
AND
Add “No specific underserviced/distinct
group” to list of options.
AND
Remove Title 1 Schools from list of
options.
Mission of
Organization

Reduce character count from 1,500 to
750.

OT
Fiscal Health of
Organization

Decrease of 750
characters from this
year.

Reduce character count from 1,000 to
750.

Decrease of 250
characters from this
year.

OT
Mission/Purpose Reduce character count from 1,500 to
of Partner
750.
Organization

Decrease of 750
characters from this
year.

OT
Primary Partner
Role

Reduce character count from 1,500 to
1,000

Decrease of 500
characters from this
year.

Reduce character count from 1,000 to
750.

Decrease of 250
characters from this
year.

OT
Intended
Beneficiaries/
Audience/

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Participants/
Community

14

AND

OT

Remove beneficiary consultation
subquestion.

Community
Engagement

Reduce character count from 2,000 to
1,000.

Decrease of 1,000
characters from this
year.

Reduce character count from 1,000 to
750.

Decrease of 250
characters from this
year.

OT
Project
Participants,
Individual and
Partners
OT
Project Activity
Dropdowns
ORA

Eliminate these dropdown questions:
•
•
•
•
•
•
•

Project Activity Category (for
project tracks)
Study Area
Topic Area
Research Methods
Intervention/Control
Primary Data Collection Y/N
Project Artistic Discipline

ORA

Eliminate “Descriptions about relevant
prior research” question

ORA

Merge Operating History List into
Background/History of Organization.
AND

Decrease of 5,000
characters from this
year.
Overall decrease of
7,500 characters from
this year.

Increase Background/History of
Organization character count from 1,000
to 4,000.
Literature
Fellowships

Eliminate Cover Page (CWF only).
AND
Collect title of work on the SF-424 (CWF
only).

CWF=Creative Writing
Fellowships

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AND
Request penname (if applicable) and
email on the Summary of Applicant
Publications (CWF and Translation).
Accessibility
Form

NHPA/NEPA
Form

Clarifying language has been added for
SAAs, RAOs, and LAAs only to address
how their own organization meets
accessibility requirements and how they
obtain compliance information from
subgrantees.
Clarifying language has been added to
multiple questions.
No net increase on burden.