Statement A for non-substantive change

Extension of the Generic Clearance Authority

OMB Control Number 3136-0134

Justification: Supporting Statement A

Supplemental Request: June 9, , 2022

Abstract

The National Endowment for the Humanities (NEH) received a three-year renewal of its generic clearance authority, OMB control number 3136-0134, in October 2021. This clearance includes NEH’s Notice of Funding Opportunity (NOFO) template, agency-specific application and award-related forms, and agency-specific performance reports. NEH seeks to increase the burden estimate under this clearance and to approve additional information collections.

Type of Request

This is a request for an increased burden estimate and additional information collections under existing clearance 3136-0134. This request includes sixteen new information collections with a total burden estimate of 1,897 hours, increasing the total burden estimate from 300,160 hours to 302,057 hours and $21,235,922 to $21,370,153.72.

1. Need for the Collection

NEH’s primary function is grantmaking, and this clearance authority covers information collections related to this activity. They allow the agency to:

• solicit grant applications from the public

• recruit peer reviewers from the public

• process awards

• monitor recipient performance

NEH programs are authorized by 20 U.S.C. § 956, et seq. Awards are subject to 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards.

This clearance currently covers 23 information collections. At this time NEH requests approval for an additional 16 information collections, summarized below. The majority of these requests are program-specific iterations of the already cleared NEH interim and final performance report templates.

Information Collection	Brief Description
1. Performance Report: Fellowships for Advanced Social Science Research on Japan	Individuals complete this report online in eGMS Reach within 120 days of the period of performance end date, consistent with 2 CFR 200.
2-3. Interim and Final Performance Reports: State Humanities Councils “A More Perfect Union”	State humanities councils complete this report online in eGMS Reach within 120 days of the period of performance end date, consistent with 2 CFR 200.
4. State Humanities Councils Regrant Summary Report	State humanities councils submit this report to identify organizations and individuals selected as subrecipients.
5. Final Performance Report: Preservation Assistance Grants (PAG)	PAG recipients complete this report online in eGMS Reach within 120 days of the period of performance end date, consistent with 2 CFR 200.
6. Performance Report: Division of Education Programs	Division of Education Programs recipients complete this report online in eGMS Reach within 120 days of the period of performance end date, consistent with 2 CFR 200.
7. Performance Report: Division of Public Programs: Cooperative Agreements and Special Project	Division of Public Programs recipients complete this report online in eGMS Reach within 120 days of the period of performance end date, consistent with 2 CFR 200.
8. Performance Report: Digital Projects for the Public	Digital Projects for the Public recipients complete this report online in eGMS Reach within 120 days of the period of performance end date, consistent with 2 CFR 200.
9-10. Performance Reports: Media Projects: Development and Media Projects: Production	Media Projects: Development and Media Projects: Production recipients complete this report online in eGMS Reach within 120 days of the period of performance end date, consistent with 2 CFR 200.
11-13. Performance Reports: Public Humanities Projects (Implementation, Planning, Humanities Conversations)	Public Humanities Projects recipients complete this report online in eGMS Reach within 120 days of the period of performance end date, consistent with 2 CFR 200.
14. FPIRI Fellowship Data Form	This form asks individual participants in NEH-funded FPIRI fellowship programs to report on their experience.
15. FPIRI Financial Report	FPIRI recipients provide a summary budget for their programs.
16. Program Income Report	Media Projects recipients are required to report program income for up to seven years following the period of performance, consistent with agency policy.

2. Information Use

Respondents to these additional information collections are NEH grant recipients (both organizations and individuals). NEH uses this information internally and does not disseminate it publicly.

NEH uses various reporting templates to monitor recipient performance in compliance with relevant governmentwide regulations, agency policy, and program-specific requirements.

In the past, NEH has used the information collections under this clearance to support our grants management; we plan to continue such efforts under this extension.

3. Information Collection Method

NEH conducts all information collections online. Recipients submit their reports and forms via eGMS, NEH’s electronic grants management system. NEH staff oversee all collections.

Except as required by 2 CFR § 200.329, NEH requires recipients to submit performance reports annually.

4. Duplication

When appropriate, NEH uses existing collections, such as the SF-424 – Short Organizational, Research and Related Budget, and Federal Financial Reporting Form. In other instances, NEH modifies existing forms as a basis for its collections – for example, many NEH reports included in this request are based on the basic Performance Progress Report with the addition of agency/program-specific questions.

5. Minimizing Burdens on Small Businesses

NEH is committed to streamlining its application process and reporting requirements, striving to balance the need for information with preventing undue burden on its applicants. The agency's internal clearance process ensures that NEH does not place an undue burden on applicants seeking NEH funding.

6. Consultation Outside of the Agency

NEH published notices in the Federal Register to solicit public comments on this proposed extension on January 27, 2021, and April 6, 2021. The agency received one public comment, dated January 27, 2021, which expressed general concern about the benefit of this information collection to the taxpayer. NEH acknowledged the comment but determined that it did not call for any change since the opinion expressed was of a general nature and did not pertain to any specific information collections included in this request.

7. Estimation of the Annual Burden and Costs of the Collection

Information Collection Activity	Type of Collection	Number of Respondents	Total Annual Responses	Hours Per Response	Total Hours
1. Performance Report: Fellowships for Advanced Social Science Research on Japan	Report Template	3	3	1 hour	3
2. Interim Performance Report: State Humanities Councils “A More Perfect Union”	Report Template	56	56	4 hours	224
3. Final Performance Report: State Humanities Councils “A More Perfect Union”	Report Template	56	56	5 hours	280
4. State Humanities Councils Regrant Summary Report	Report Template	56	56	8 hours	448
5. Final Performance Report: Preservation Assistance Grants	Report Template	70	70	2 hours	140
6. Performance Report: Division of Education Programs	Report Template	200	200	2 hours	400
7. Performance Report: Division of Public Programs: Cooperative Agreements and Special Project	Report Template	3	3	2 hours	6
8. Performance Report: Digital Projects for the Public	Report Template	28	28	2 hours	56
9. Performance Reports: Media Development	Report Template	7	7	2 hours	14
10. Performance Reports: Media Production	Report Template	29	29	2 hours	58
11. Performance Reports: Public Humanities Projects (Implementation)	Report Template	47	47	2 hours	94
12. Performance Reports: Public Humanities Projects (Planning)	Report Template	26	26	2 hours	52
13. Performance Reports: Public Humanities Projects (Humanities Conversations)	Report Template	11	11	2 hours	22
14. FPIRI fellowship data form	Report Template	70	70	10 minutes	12
15. FPIRI Financial report	Report template	13	13	1 hours	13
16. Program income report	Report Template	50	50	1.5 hours	75

We estimate a total annual burden for these sixteen new collections at 1,897 hours and $134,231.72.

We estimate the cost to the Federal Government for these sixteen new collections to be $51,301. (NEH staff spend approximately one hour reviewing each report).

Both respondent and NEH staff time is estimated at $70.76 per hour.

8. Explanation of Changes in the Burden of the Collection

The total burden estimate for this clearance has increased based on the inclusion of sixteen new information collections not previously included.

9. Payment or Gift to Respondents

NEH does not provide payments or gifts to any respondents.

10. Justification for Sensitive Questions

NEH does not solicit information on sexual behavior, religious beliefs, or other personal matters.

11. Privacy and Confidentiality

None of the information collections included here include personally identifiable information.

The Federal Register citation for NEH’s System of Records Notice (SORN) is Vol. 82, No. 79.

12. Expiration Date for OMB Approval

NEH will include the expiration date on all information collections covered by this clearance.