FDR Supporting Statement 2021 10.15.21

National Endowment for the Arts Supporting Statement
NEA Funding Reporting Requirements - Final Descriptive Reports Update
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: 201908-3135-001 / OMB Control #31350112). Awards are made to nonprofit organizations, government agencies, and
individuals.
In concordance with OMB 2 CFR part 200, Final Descriptive Reports (FDR) elicit
information on project activities and expenditures from individuals, nonprofit
organizations, and government arts agencies that receive funding from the National
Endowment for the Arts (see ICR Reference No: 201908-3135-001 / OMB Control
#3135-0112 for more detail on these programs). 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
participation in and location of project activities to understand the reach and
geographic distribution of NEA-approved grant and cooperative agreement activities.
Participation data, including in-person and virtual engagement counts and
demographic characteristics of populations served, is collected in the FDR form.
Geographic information 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.
The agency previously submitted a clearance package for FDRs (OMB Control #
3135-0140) and we will continue to use this same OMB Control number for the
proposed clearance package.
This year, in addition to minor updates to forms, we are including three new forms: a
participation list for our Poetry Out Loud national initiative; and 2 data collection
forms for our Creative Forces Community Engagement initiative. The participation
list is used to collect information on the names of schools and organization who held
competitions and their geographic locations. The Creative Forces Community
Engagement forms will be used to gather information from applicants and
subgrantees regarding the details of the programs they intend to offer for military

service members and veterans exposed to trauma as well as their families and
caregivers, the number of participants at events or sessions, changes in capacity of
the subgrantee and its partner(s), and details of the populations that benefited from
the programs.
In addition, there are 3 forms (FY19-22 General Operating Support FDR, American
Rescue Plan Local Arts Agencies (ARP LAA) FDR form, and LAA subgrant
spreadsheet) that were cleared early this year through an emergency clearance (see
ICR Reference No. 202104-3135-004 / OMB Control # 3135-0143). The FY19-22
General Operating Support FDR was designed to account for Congressionallyapproved changes to how funds were able to be spent as a result of the COVID-19
pandemic under our regular grant programs. Previously, our funds and therefore, the
final reports elaborating how they were spent were project focused. Grantees were
able to reallocate funds to general operating support, so the General Operating
Support FDR was created. 2020 Coronavirus Aid, Relief, and Economic Security
(CARES) Act funds and 2021 American Rescue Plan (ARP) funds are also able to
be used to support general operating costs and the FY19-22 General Operating
Support FDR will also be used to track funds from these grant programs. This form
was generated to account for this change. The ARP LAA FDR was generated
specifically to track ARP funds allocated to local arts agencies. The LAA subgrant
spreadsheet is designed to further track how local arts agencies allocate ARP funds
to subgrantees.
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.
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 Office of Grants Management staff and
then turned over to the respective discipline offices for review.
The Office of Research and Analysis uses FDR data for analysis and evaluation of
grant programs. Findings from the analysis of FDR data are also used in the
Agency’s Annual Performance Report, which is submitted to OMB and Congress.
All Creative Forces applicants will be required to submit the supplemental
application form to Mid-America Arts Alliance, which is a cooperator for the NEA,
that will manage the subgranting program on behalf of the NEA. All Creative Forces
subgrantees will be required to submit the Creative Forces Final Descriptive Report
form to the Mid-America Arts Alliance. The Mid-America Arts Alliance will review the
Supplemental Application Forms and Creative Forces Final Descriptive Report forms
and provide the cleaned data set (including de-identification), documentation of
analytical methods, and data tables requested by the Agency. The data will be used
by the NEA Office of Research and Analysis and the NEA Office of the Senior

Deputy Chairmen to assess the effectiveness of projects, the organizations and
populations who benefit from federal dollars, and the geographic locations where
federal grant dollars were spent.
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 from fiscal
year 2020 and later and the GEO portion of the Final Report are fillable webforms
submitted through NEA’s online awards management system, REACH. Final
Descriptive Report forms from fiscal year 2019 and earlier are submitted as fillable
PDF forms. In addition, the Participation List for the Poetry Out Loud initiative and
the LAA subgrant spreadsheet are Excel spreadsheets to be filled out by grantees
and submitted to NEA program staff as instructed in the Manage Your Award tab.
The Creative Forces Community Engagement forms will be required to be submitted
by applicants and subgrantees to the Mid-America Arts Alliance via a web form on
Mid-America’s online application portal. Organizations are able to save their data in
the webform and, as applicable, the Creative Forces Community Engagement Final
Descriptive Report form will pre-populate with information from the application form.
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.

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
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 60-day notice for public comment was published in the Federal Register, Vol. 86,
38505 (document 2021-15500) on July 21, 2021, to solicit comments on the “2021
Final Descriptive Report Update” 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. A 30-day notice for public
comment was also published in the Federal Register, Vol. 86, 57454 (document
2021-22532) on October 15, 2021.
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
renumeration of contractors or grantees.
Not applicable. The National Endowment for the Arts 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 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 that receive
funding awards from the National Endowment for the Arts. Figures are based on a
frequency of one response per year for reporting.

Type of Recipient

Est. # of
Grant
Reports

Average
Time per
Report

Est. Reporting
Burden for Grant
Reports (Hours)

Nonprofit Orgs

11,525

2.5

28,813

Gov Agencies

1,782

3.8

6,772

1

97

Individuals
Totals

97
13,404

35,682

The total reporting requirements burden is estimated at 35,682 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 35,682 hours.
With an agency-wide estimate of 13,404 grantees, this works out to an agency
average of approximately 2.66 hours per response. This agency-wide average
includes both nonprofits and government agencies whose reporting burden is
estimated at 2.5 and 3.8 hours, respectively, and individuals where the estimate is 1
hour per grantee. Note that these estimates reflect the approximate number of
reports we expect to receive annually, but also include reports we expect to receive
from prior years. Because some grants are multi-year awards, grant reports are
received unevenly.
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

11,525

2.5

28,813

$24.50

$705,919

1,782

3.8

6,772

$24.50

$165,914

97

1

97

$45

$4,365

13,404

TOTAL COST TO RESPONDENTS = $876,198
The total estimated burden to grantees is $876,198.

$ 876,198

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 ($33/hour) and 50% for support staff ($16/hour). 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 reports. Salaries
for personnel at nonprofit organizations and government 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. Salaries for individuals were estimated based on 1) 2020-2021 average
salaries for assistant professors and instructors at U.S. 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
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.
COST TO FEDERAL GOVERNMENT
NEA Application/Report Review

Type of
Review
Reports

Est. #
Grants
13,404

Average # of
Hours per
Application
or Report
2

Total
Hours
26,808

Average
Hourly
Wage
$54.50

Total
$1,461,036

COST TO FEDERAL GOVERNMENT = $1,461,036
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 hours per report by a Final Reports Officer
(average wage GS 12/Step 10). The pay here, coupled with a 30.48% fringe benefits
rate, provides an estimated hourly rate of $54.50. 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.
Final Descriptive Reports were previously approved under OMB Control #3135-0140
(see ICR Reference No. 201809-3135-002). 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. From submission of the previous PRA package in 2018 to the current
submission, our overall estimated number of grants has increased, from 2,507 in our
last submission three years ago, to a current estimate of 10,401. This number
represents an increase in application numbers from nonprofits, government, and
from individuals. NEA received funds from the CARES Act and the American
Rescue Plan, which increased the number of grantees and therefore, report forms
substantially in 2020, 2021, and 2022. These programs collectively increased the
number of reports the agency expects to receive by over 3500. In addition, the
current PRA package includes three additional forms, two of which are related to a
new program, that expect to receive over 350 additional reports.

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.
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
and performance 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 identisfied 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.