FDR Supporting Statement 2022

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 Chair of the National Endowment for the Arts (NEA) 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 Chair establishes eligibility requirements and criteria for the review of
applications (see OMB Control #3135-0112). 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 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 NEA 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 Descriptive
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 are revising this clearance package.
We are adding six new forms to the PRA package cleared in March 2022 (ICR
Reference No. 202110-3135-002 / OMB Control # 3135-0140): FY24 Standard FDR
form, FY24 Arts Education FDR form, FY24 Our Town FDR form, FY24 SAA-RAO
FDR form, FY24 Research FDR form, and the FY24 Subgrant Spreadsheet.
The FY24 Standard FDR form, FY24 Arts Education FDR form, FY24 Our Town
FDR form, and FY24 SAA-RAO FDR form are based largely on the corresponding
FY20 and Later FDR forms that were cleared in March 2022. The following
substantial changes were made globally across this set of forms:

1) reordered and reworded narrative questions and an added progress monitoring
question,
2) revised key partner entity type dropdown list to include additional options, such
as minority-serving institutions,
3) removed the project activity section to reduce burden,
4) revised the individuals benefitted section to include more specific guidance for
reporting attendance numbers for in-person and virtual activities and added a
question regarding how attendee counts were generated, and
5) added a definition of underserved groups/communities and revised the
corresponding Underserved Groups/Communities population descriptors section.
In addition to global changes, there are some unique changes:
A) The FY24 SAA-RAO FDR form now includes a cost share/match field to aid the
Agency’s Office of Grants Management in ensuring subgrant reporting
compliance. In addition, population descriptor questions were removed rather
than revised due to the intricate coordination necessary to update the National
Standard. The National Standard for Arts Information Exchanges (a.k.a. “the
Standard”) is a taxonomy of data fields used by state arts agencies and regional
arts organization, in coordination with the National Endowment for the Arts, as a
means to collect and analyze compatible information about constituents, projects,
activities, and resources. These questions will be revised to match the format of
the new population descriptors when the National Standard is updated in FY25.
B) A new form was added (FY24 Research FDR), which is specifically tailored to the
Agency’s Research Grants in the Arts and Research Labs programs. Previously,
grantees in these programs filled out the Standard FDR form that contains
sections that were not relevant for these grant programs.
C) The FY24 Subgrant Spreadsheet is largely based on the ARP LAA Subgrant
Spreadsheet that was cleared in March 2022. The project-specific section (blue)
of the spreadsheet was adjusted to match the FY24 Standard FDR Individuals
Benefitted fields and the use of LAA was changed to “prime recipient” to ensure
the form can be for general use across all Agency subgranting programs.
D) A narrative question inquiring about short-term outcomes specific to the Our
Town program were added to the FY24 Our Town FDR. The question is based
on results from a previous evaluation study, an approach encouraged by
OMB/OIRA.
E) The FY24 Arts Education FDR was revised to streamline the narrative questions
for Direct Learning and Professional Development projects. The Collective
Impact questions were revised in response to OMB/OIRA feedback that
suggested NEA focus on early indicators rather than long-term impacts of grant
projects.
F) The Creative Forces SAF was revised to update the responses on the first two
questions to match the defined outcomes of the grant program and logic model.

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 (FDR), and subgrant data as relevant, are required to be
submitted by grantees/prime recipients 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 NEA Office of Research and Analysis uses FDR and subgrant data for analysis
and evaluation of grant programs. In the case of subgrants, this data is used to
understand the full reach of NEA grantmaking which extends beyond direct grant
awards. Subgrant data is also collected to ensure their compliance with terms and
conditions of federal grants. Findings from the analyses of this data are also used in
the Agency’s Annual Performance Report, which is submitted to OMB and
Congress.
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 (FDR) must be submitted to the Agency electronically. The NEA posts all of
the instructions and forms for its reporting requirements on its website, under the
Manage Your Award tab. FDRs 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. FDRs from fiscal year 2019 and earlier are submitted
as fillable PDF forms. In addition, the new Participation List for the Poetry Out Loud
initiative, the LAA Subgrant spreadsheet, and the new FY24 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. Additional forms, as relevant, use
either electronic fillable webforms or PDF forms.
The NEA has refined its electronic reporting systems in response to governmentwide initiatives (such as the Foundations for Evidence-Based Policymaking Act of
2018) 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 NEA’s funding opportunities and subsequent awards are aimed
specifically at sections of the country, areas of cities, and rural areas that may not be
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 NEA’s 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;

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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. 87,
32465 (document 2022-11603) on May 31, 2022, to solicit comments on the “2022
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. 87, 54547 (document
2022-18845) on September 6, 2022.
NEA 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. In July 2022, NEA staff
members consulted with organizations who had recently submitted an FDR to the
agency. This group of former grantees cognitively tested the new key partners
question and the virtual engagement question that were added to the new FDRs.
The feedback from these focus groups was incorporated into the new forms. NEA
cooperator National Assembly of State Arts Agencies (NASAA) also facilitated a
focus group discussion with representatives from state arts agencies and regional
arts organizations to collect feedback on the individuals compensated and
individuals engaged in arts experiences sections of the FDR form. NASAA asked
representatives questions related to their ability to collect audience counts from
virtual, in-person, and hybrid events and their ability to collect data on individuals
compensated; feedback from this consultation will inform future revisions to the
National Standard.
9. Explain any decision to provide any payment or gift to respondents, other than
renumeration 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:
• 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,

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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 NEA. 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

13,835

2.6

35,971

Gov Agencies

1,906

3.8

7,243

1

97

Individuals
Totals

97
15,838

43,311

The total reporting requirements burden is estimated at 43,311 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 43,311 hours.
With an agency-wide estimate of 15,838 grantees, this works out to an agency
average of approximately 2.73 hours per response. This agency-wide average
includes both nonprofits and government agencies whose reporting burden is
estimated at 2.6 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.
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

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(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.

COST TO RESPONDENTS/REPORTING

Type of
Recipient
Nonprofit
Orgs
Gov
Agencies
Individuals
TOTALS

Est. # of
Grants

Average
# of
Hours
Total Hours
per
Grant
Report

Average
Hourly
Total
Wage

13,835

2.6

35,971

$24.50

$881,290

1,906

3.8

7,243

$24.50

$177,454

97

1

97

$45

$4,365

15,838

TOTAL COST TO RESPONDENTS = $1,063,109
The total estimated burden to grantees is $1,063,109

$ 1,063,109

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.
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
15,838

Average # of
Hours per
Application
or Report
2

Total
Hours
31,676

Average
Hourly
Wage
$54.50

Total
$1,726,342

COST TO FEDERAL GOVERNMENT = $1,726,342
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 #31350140. 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 the addition of new forms to be issued alongside future grant awards.
From submission of the previous PRA package in 2021 to the current submission,
our overall estimated number of grants has increased, from 13,404 in our
submission earlier this year, to a current estimate of 15,838. This number represents
an increase in application numbers from nonprofits and government. The new forms
will be issued to grantees of awards that will be made in the future. The forms that
were previously cleared are still in use currently, so the new forms represent data
collections to be added to the preexisting collections. To reduce burden, we have
removed older forms (FY12-14 Standard and FY12-14 Livability) from the package
that are no longer in use.
The NEA 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.
FDRs 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 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.