International Indemnity Supporting Statement A 2020

National Endowment for the Arts Application for International Indemnification Supporting
Statement
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.
This form is used by organizations applying to the Federal Council on the Arts and the
Humanities (through the National Endowment for the Arts) for indemnification of eligible arts
and artifacts, borrowed from abroad for exhibition in the United States, from within the United
States when the foreign works of art are integral to the exhibition, or sent from the United
States for exhibition abroad. The indemnity agreement is backed by the full faith and credit of
the United States. In the event of loss or damage to an indemnified object the Federal
Council certifies the validity of the claim and requests payment from Congress. The Arts and
Artifacts Indemnity Act (P.L. 94-158) requires such an application and specifies information
which must be supplied. This statutory requirement is implemented by regulation at 45 C.F.R.
1160.4.
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.
Applicants are non-profit entities, usually museums that organize traveling exhibitions.
Applications are reviewed by the Indemnity Advisory Panel and the Federal Council on the
Arts and the Humanities to determine whether to issue a Certificate of Indemnity. Applications
are necessary in making that decision.
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.
Information about Indemnity, including how to apply for coverage, is available on the Arts
Endowment’s website. The website provides a direct link to the application package on
Grants.gov and NEA Applicant Portal. Applicants are asked to submit their application
packages electronically through Grants.gov (SF-424) and NEA Applicant Portal (all
materials).
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.
This information is not reported through any other sources. Applicants apply for a single,
specific exhibition to be indemnified.
5. If the collection of information impacts small businesses or other small entities,
describe any methods used to minimize burden.
Museums that organize international exhibitions are not small entities.

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 application for indemnity is a one-time submission which an applicant makes prior to an
exhibition. It could not be made less frequently.
7. Explain any specific circumstances that would cause an information collection to be
conducted in a manner:
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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.
None.

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.
Notice for comment was published in the Federal Register. No comments were received. The
members of the Advisory Panel and the Federal Council are consulted quarterly, to obtain
their views and incorporate their recommendations for changes in the application and
instructions.

9. Explain any decision to provide any payment or gift to respondents, other than
remuneration of contractors or grantees.
Not applicable.
10. Describe any assurance of confidentiality provided to respondents and the basis for
the assurance in statute, regulation, or agency policy.
No assurance of confidentiality is provided.
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.
This application does not contain questions of a sensitive nature such as matters concerning
sexual behavior and attitudes, religious beliefs, and other matters commonly considered
private.
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 in Item 13.
• 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 13.
An estimated 40 respondents per year complete this form. It is estimated that respondents
spend an average of 44 hours and forty minutes completing this form, and twenty minutes
completing the SF-424. The application for indemnification is a one-time submission. No
additional form is required. Although the costs to respondents vary depending upon the
complexity of the exhibition, i.e., the number of objects in the exhibition, the number of
lenders, and the number of exhibition sites, it is estimated that the average cost to
respondents is $2,097. This estimated cost includes staff time, charges for telephone, fax,
and copying, and other support services. The cost burden and COLA for this information
collection was based on average salaries for curators and registrars (the positions of
applicants who generally will be completing the Indemnity Application) from art museums.
13. Provide an estimate for the total annual cost burden to respondents or recordkeepers
resulting from the collection of information. (Do not include the cost of any hour
burden shown in Items 12 and 14).
• 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

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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 collections 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.
None.

14. Provide estimates of annualized costs 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, overhead, 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.
The estimated cost of this Program to the Government is $288,154 annually, which includes
two staff salaries, staff travel, printing and mailing of written material, and, infrequently, the
need to pay for the services of an insurance adjustor.
15. Explain the reasons for any program changes or adjustments reported in Items 13 or
14 of the ICR.
The increase in the estimated cost of this program to the Federal government is due to a
change in staff and salaries/benefits.
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.
There are no plans to publish collections of information for statistical use.
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.
Not applicable.
18. Explain each exception to the certification statement identified in Item 19,
"Certification for Paperwork Reduction Act Submissions.”
Not applicable.