NEA Supporting Statement A

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National Endowment for the Arts (“NEA”) Supporting Statement
Justification for NEA Notice of Funding Opportunities in Response to the
American Rescue Plan Act of 2021 ("Rescue Plan")
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 American Rescue Plan Act of 2021 authorizes the NEA Chairman to carry out a
program of grants-in-aid for proposals that focus on COVID-19 pandemic relief as
follows:
2021. NATIONAL ENDOWMENT FOR THE ARTS.
In addition to amounts otherwise available, there is appropriated for fiscal year
2021, out of any money in the Treasury not otherwise appropriated,
$135,000,000, to remain available until expended, under the National
Foundation on the Arts and the Humanities Act of 1965, as follows:
(1) Forty percent shall be for grants, and relevant administrative expenses, to
State arts agencies and regional arts organizations that support organizations’
programming and general operating expenses to cover up to 100 percent of the
costs of the programs which the grants support, to prevent, prepare for, respond
to, and recover from the coronavirus.
(2) Sixty percent shall be for direct grants, and relevant administrative expenses,
that support organizations’ programming and general operating expenses to
cover up to 100 percent of the costs of the programs which the grants support, to
prevent, prepare for, respond to, and recover from the coronavirus.
PRA emergency clearance for NEA’s Rescue Plan NOFOs was granted by OMB in
June 2021 (OMB Control Number: 3135-0143). This request is to approve, for a
period of three years, these NOFOs through OMB’s regular clearance process
This program will be administered in accordance with the agency’s enabling
legislation (20 U.S.C. §954), which requires grant application review by advisory
panelists and the National Council on the Arts. The NEA anticipates that the limited
federal funds available under the Rescue Plan will not allow for funding of all of the
qualified requests that it receives. Competitive review of applications for financial
assistance will be performed by advisory panelists and the National Council on the
Arts. The NEA Chairman reviews the Council’s recommendations and makes the
final decision on all awards. The information that is collected through the Rescue
Plan NOFOs is necessary to review these grant applications. This information is

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necessary for the accurate, equitable, and thorough consideration of competing
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.
NEA staff will make the information gathered in response to the NOFOs available to
the advisory panelists with the appropriate expertise. Each panel comprises a
diverse group of arts experts and other individuals including at least one
knowledgeable layperson.
The NOFOs ensure that all applicants submit comparable information. Without the
specific instructions provided by the NOFOs, applications would vary 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 NEA 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.
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 NEA makes all of its NOFOs available on its website and places application
packages for all of its funding categories on Grants.gov. Our NOFOs 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 NEA’s online applicant portal via a webform. (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.)
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 NEA uses standard Grants.gov forms for all of its electronic applications,
namely the SF-424-Short for nonprofit and related organizations. In addition,
responses to narrative and budget questions are submitted electronically through a
webform accessible via the NEA’s online Applicant Portal.

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The NEA usually supports project-based funding for arts organizations only. The
Rescue Plan legislation, however, specifies that funds be available for general
operating expenses. As a result, the NEA has created Rescue Plan NOFOs that will
gather the information necessary to assess these applications and their proposed
costs and to make grant awards. NOFOs will be available for two Rescue Plan
funding opportunities: one for Grants to Organizations, and another for Grants to
Local Arts Agencies for Subgranting programs. Since each program has a different
pool of eligible applicants and allowable costs, different NOFOs are necessary.
5. If the collection of information impacts small businesses or other small
entities, describe any methods used to minimize burden.
The NEA is highly cognizant of the pressures facing all of the arts sector at this
troublesome time and is especially sensitive to the constraints faced by small,
independently-run, nonprofit organizations, as well as the expedited nature of the
Rescue Plan. Therefore, special attention has been given to minimizing the burden
on applicants throughout the development of these NOFOs.
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 timelines necessary to receive,
review, and commit stimulus funds to help support jobs. These programs have been
developed to expedite the distribution of funds at this critical time. Applicants are
limited to a single application to support specific general operating expenses or
subgranting programs. The collection of information is in direct response to this
opportunity.
Panelists review applications on their merits and in competition with other
organizations' applications for arts funding under the Rescue Plan. If the requested
information was not collected, panelists would not have timely or accurate
information on which to base their evaluations. The NEA would be unable to ensure
the equitable, fair, and accountable use of federal funds.
7. Explain any special 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;

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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 NEA is planning to issue NOFOs for two Rescue Plan programs: 1) Grants to
Organizations; and 2) Grants to Local Arts Agencies to support subgranting
programs in their respective communities. The collection of information for these
NOFOs will include a response time of at least 30 days to ensure equitable and wide
access to these funding programs.
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 (86 FR 35367; Document Number:
2021-13540) on July 2, 2021, to solicit comments on the “NEA American Rescue
Plan Act of 2021 Grants to Organizations and Grants to Local Arts Agencies for
Subgranting Notice of Funding Opportunities (NOFOs)” prior to submission of this

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OMB clearance request. No public comments were received at the NEA 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.
NEA 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 NEA 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 NEA 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:
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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

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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 APPLICATIONS
The chart below is broken out by type of recipient. Figures are based on a frequency of
one response per applicant.
Type of
Recipient

Est.
Average Est.
# of
Time
Reporting
Apps per App Burden for
Applications
(Hours)

Grants to
8,500
Organizations
AND Grants
to Local Arts
Agencies for
Subgranting

7

59,500

TOTALS

7

59,500

8,500

Time estimates are the same for both Rescue Plan NOFOs (Grants to Organizations
and to Local Arts Agencies for Subgranting Programs). The total annual burden is
estimated at 59,500 hours. This burden is calculated by multiplying the estimated
number of applications for each program x the estimated average hourly response
burden of 7 hours x 1 response per year. NOTE: The time estimate listed in the NOFOs
is 8 hours: this includes 1 hour to complete the SF-424 short organization form (as
estimated by Grants.gov) plus 7 hours to complete all of the other application
requirements specified in the NOFOs.
COST TO RESPONDENTS/APPLICATIONS

National Endowment for the Arts Supporting Statement

Type of
Recipient

Est. #
of
Apps

Grants to
Organizations
AND Grants to
Local Arts
Agencies for
Subgranting
Programs

8,500

TOTALS

8,500

Average #
of Hours
per
Applicatio
n

Total
Hours

Average
Hourly
Wage

7

Total

3.5 (Prof
Staff)

29,750

$33

$981,750

3.5 (Spt
Staff)

29,750

$16

$476,000

59,500

$24.5

$1,457,750

The total estimated cost burden to applicants is $1,457,750. 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. This
division of labor is estimated at approximately 50% for professional staff and 50% for
support staff. The average hourly wage of $24.50 was computed factoring in
professional support staff wages proportionate to the amount of time each typically
spends preparing applications and reports. Salaries for personnel at nonprofit
organizations and local arts agencies were estimated based on 1) salaries provided in
the NEA’s most recent submission under PRA; and 2) a sampling of salaries presented
in current applications; and 3) 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 shown in Items 12 and 14.)
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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 GOVERNMEN for NEA Application Review
Type of
Review

Applications
TOTAL

Est. #

8,500

Average #
of Hours
per
Applicatio
n or
Report
6

Total
Hours

51,000

Average
Hourly
Wage

$65.00

Total

$3,315,000
$3,315,000

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TOTAL COST TO FEDERAL GOVERNMENT = $3,315,000
In the chart above, the estimated number of hours for staff review of applications is
based on staff experience with similar tasks in the past. The Average Hourly Wage
is based on the following. The review of applications is projected to average 6 hours
each, with this time split as follows: Program Director at 1 hour; Grants Management
Specialist at 4 hours; and Support Staff at 1 hour. We averaged the pay of a GS15/Step 5 Program Director, a GS-12/Step 5 Grants Management Specialist, and a
GS-9/Step 1 Support Staff person (using the Office of Personnel Management
Salary Tables for the D.C. area) to come up with an average hourly rate of $50. To
this, we added 31% fringe benefits for a total average hourly wage of $65.
15. Explain the reasons for any program changes or adjustments reported in
Items 13 or 14 or on the ICR.
This is a new collection of information in response to the Rescue Plan. Figures are
new and do not reflect adjustments to previously reported information.
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.