NEA Supporting Statement A 2022 Final

9/1/2022
National Endowment for the Arts Supporting Statement
Blanket Justification for NEA Funding Application Guidelines and Requirements
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 NEA Chair establishes eligibility requirements and criteria
for the review of applications. Applications for funding are accepted at different
deadlines throughout the year for a variety of arts projects from nonprofit
organizations, government agencies, and individuals.
The NEA has limited federal funds and cannot fund all of the eligible requests that it
receives. Competitive review of applications for financial assistance is performed by
advisory panelists and the National Council on the Arts (currently composed of 18
Presidentially-appointed members and three members of Congress who serve ex
officio). The Council sends forward to the NEA Chair those applications that it
recommends for funding. The NEA Chair reviews the Council’s recommendations
and makes the final decision on all awards. The information that is collected on the
application form and accompanying supplemental materials is used in the review
process. This information is necessary for the accurate, fair, and thorough
consideration of competing funding 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 post to an online application review system the completed application
forms and other information submitted by grant applicants so that advisory panelists
may review these materials. Each advisory panel comprises a diverse group of arts
experts and other individuals including at least one knowledgeable layperson. Panel
membership rotates regularly.
The application guidelines ensure that all applicants submit comparable information.
Without the specific instructions provided by the guidelines, applications would vary
in length, format, and consistency and the job of reviewing them would be
untenable. If this information was not collected (or not collected in a standardized
manner), advisory panelists, the National Council on the Arts, and the NEA’s Chair
would not have the basis on which to make sound evaluations and

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recommendations. Arbitrary or random methods would be required to select
applications for funding.
Information that is collected on the application forms also is used for breakdowns of
our applications—for example, by arts discipline, by project type, by type of
organization, etc.—and for assessing the agency’s performance in carrying out its
strategic goals and objectives.
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 application guidelines available on its website and places
application packages for all of its funding categories on Grants.gov. The guidelines
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 (for certain funding
categories only). Waivers are extremely limited, available only to those who do not
have internet access available within 30 miles of their address or in cases where
disability prevents the submission of an electronic application.
The NEA has greatly refined its electronic application systems in response to
government-wide initiatives and to the agency’s desire to improve efficiency and the
reliability and usefulness of the information collected. Most applicants submit a
majority of their applications via consolidated webforms located on the agency’s
Applicant Portal whenever possible. This has created efficiencies for staff by
electronically validating what is submitted, as well as providing easy access to
information in data fields for dissemination, decision-making, and research
purposes. Applicants have benefited from these efficiencies as well. Instead of
submitting multiple application forms as PDF attachments, they enter information
into one webform. We continually explore ways to refine our information technology
systems for the benefit of applicants, panelists, 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 NEA uses Grants.gov’s standard Application for Federal Domestic Assistance
forms for all of its electronic applications: SF-424 Mandatory for government
agencies; SF-424-Short for nonprofit organizations; and the SF- 424-Individual for
individuals.

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We have three basic sets of forms, one for each of our major constituency types:
government agencies (notably the state arts agencies), nonprofit organizations, and
individuals. The NEA has carefully analyzed its own additional forms to make certain
that there is no duplication with the information requested by the Grants.gov forms.
We also have examined our own family of forms to see where consolidation and
uniformity was possible.
The Grants.gov and the NEA forms, together with other required supplementary
material, request the information that the agency needs to assess consistently
applications for financial assistance. Each year, most applicants apply for a single,
specific project. This project changes from year to year, as do the personnel
involved, timelines, and the project budget. Much of the information collected one
year is not relevant to the next year’s request since it is not current.
In the case of government agencies, the NEA has a continuing relationship with the
state arts agencies and their regional arts organizations and reviews plans from
these agencies that cover aspects of their programming. Full proposals normally are
reviewed only once every three years; only abbreviated updates are requested in
the “off” years.
Each set of application guidelines is reviewed regularly by a wide variety of
representatives from the field. Many of the individuals involved have been
responsible for completing applications in the past. Others, as panel members, have
taken part in the application review process. These individuals are well qualified to
help assure that only essential information is requested and that it is as nonduplicative as possible.
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 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. In addition, all of
our application materials 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.
The collection of information correlates directly with specific application deadlines
that are listed in the guidelines. Most applicants are limited to submitting a single
application, for a specific project, each year. The project for which they apply
changes from year to year.

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Panelists review applications on their merits and in competition with other
applications in the same category. A grant awarded one year does not imply NEA
support in subsequent years. If the requested information was collected less
frequently, panelists would not have timely or accurate information on which to base
their evaluations. The NEA would be unable to ensure the fair and accountable use
of federal funds and would not be able to carry out its legislative mandate.
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 the vast majority of its information from applicants in a
manner that does not necessitate any of the special requirements noted above.
However, there are limited instances where the NEA Chair, as provided for in our
legislation, may want to respond quickly to a specific need or opportunity in the field,
particularly when this can help the NEA fulfill its goal of providing grants in areas
that are underserved. In such cases, an applicant may be asked to respond to a
collection of information in fewer than 30 days. A short turn-around time at the
application stage would be part of an expedited review and processing cycle
designed to benefit the respondent.
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

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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, Vol. 87, No. 123 (document 202213768) on June 28, 2022, to solicit comments on the “Blanket Justification for
National Endowment for the Arts Funding Application Guidelines and Requirements”
prior to submission of this OMB clearance request. One public comment was
received at the NEA in response to this notice.
Advisory panelists (approximately 700 individuals per year) 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.
In addition, NEA staff members 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 for 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].

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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 RESPONDENT BURDEN (IN HOURS) FOR APPLICATIONS
The chart below is broken out by the three basic types of recipients, which
correspond to the three basic sets of forms/supplementary material that the NEA
requests of its applicants. Figures are based on a frequency of one response per
year for applications and requirements.
Type of
Recipient

Est.
# of
Apps

Average
Time
per App

Est. Reporting Burden for
Applications (Hours)

Nonprofit Orgs

4,750

23

109,250

Gov Agencies

63*

14

882

Individuals

1,900

11

20,900

TOTALS

6,713

131,032

*Includes both full and off-year requests.

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The total annual burden (in hours) of the application guidelines is estimated at
131,032 hours. This burden is calculated by multiplying the estimated number of
applications for each type of applicant x the estimated average hourly response
burden for that type x 1 response per year. The category totals are added together
for an agency-wide estimate of 131,032 hours. With an agency-wide estimate of
6,713 applications, this works out to an agency average of 20 hours per response.
This average hours-per-response differs significantly by applicant type: from 23
hours for nonprofit organizations to 11 hours for individuals. The average for
government agencies is 14 hours, but this figure includes both the state arts
agencies and regional organizations that are submitting full proposals (due every
three years and estimated at 32 hours per proposal) and those other more
numerous agencies that are submitting only off-year updates (estimated at 8 hours
per response).
There is also some variation within the nonprofit organizations group. The estimated
application burden for most of these applicants is 26 hours. However, certain
categories of funding are designed specifically to increase access in underserved
areas and have simplified application requirements; the time burden for these
categories is estimated at 11 hours.
ESTIMATED RESPONDENT BURDEN (COST) FOR APPLICATIONS
Type of
Recipient

Est. # of
Apps

Average # of
Hours per
Application

Total Hours

Average
Hourly
Wage

Total

Nonprofit Orgs

4,750

23

109,250

$26

$2,840,500

Gov Agencies

63*

14

882

$28.35

$25,005

Individuals

1,900

11

20,900

$38

$794,200

TOTALS

6,713

$3,659,705

The total annual cost burden to applicants (in dollars) is $3,659,705. The figures
above were estimated as follows. NEA staff were consulted as to the division of
respondent time between professional staff and support staff for each type of
recipient. The average hourly wage was computed factoring in professional and
support staff wages proportionate to the amount of time each typically spends
preparing applications. Salaries for personnel at nonprofit organizations and
government agencies were estimated based on 1) salaries provided in this
submission three years ago adjusted for Cost of Living Adjustments for the past
three years; 2) a sampling of salaries presented in current applications; and 3)
consultation with NEA staff. Salaries for individuals were estimated based on 1)

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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 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.
ESTIMATED FEDERAL GOVERNMENT BURDEN FOR APPLICATIONS

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Type of Review

Est. #

Average # of
Hours per
Application

Total Hours

Average
Hourly
Wage

Total

Applications
TOTAL

6,713

6

40,278

$67

$2,698,626
$2,698,626

The total estimated annual cost to the Federal Government is $2,698,626. In the
chart above, the estimated number of hours for staff review of applications is
based on staff experience with these tasks over a number of years. The Average
Hourly Wage was developed in consultation with agency staff, based on the
following. The review of applications averages 6 hours each. Each 6 hour review
involves: 4 hours for the Program Specialist (average wage at the GS 12/5 level); 1
hour for Support Staff (average wage GS 9/1); and 1 hour for the Program Director
(average wage GS 15/6). We computed the pay of these 3 positions (using the U.S.
Office of Personnel Management’s 2022 Salary Tables for the D.C. area)
proportionately to the time spent by each, to come up with an average hourly rate of
$67. This figure includes an estimated 30.9% fringe benefits rate.
15. Explain the reasons for any program changes or adjustments reported on the
burden worksheet.
With respect to the application guidelines and requirements, the federal
government’s burden for these costs has increased since 2019 from $2,443,014 to
$2,698,626 due to Cost of Living Adjustments over the past three years, as well as
an increase in the number of applications to be processed. Similarly, the cost to
respondents for the same period of time has increased from $3,496,585 to
$3,659,705 due the same factors.
To mitigate the overall impact of these changes, we have carefully examined all of
our grant funding opportunities to see where streamlining and consolidation might
be desirable. Our efforts led us to simplify the application instructions and
requirements, improve the presentation of application materials on our website, and
refine our application webforms. As a result of these efforts, the application
instructions and requirements included in this information clearance request will not
see even a modest increase in annual applicant burden (in hours) from three years
ago. In fact, the application guidelines and requirements for nonprofit organizations
(approximately 4,750 applications per year) will see respondents’ average time
spent per application reduced by one hour—resulting in an estimated overall annual
decrease of 3,250 hours from three years ago.
A summary of changes to the NEA’s application guidelines and requirements is
included at the bottom of this document (see “2022 PRA Summary of Changes”
below).

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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).
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.
_____________________________________________________________________
2022 PRA Summary of Changes to Application Guidelines and Requirements:
Area

Detail
All Non-Profit Grant Categories

Org and Project Profile Tab Data

Updates to list of choices in various categories.

Org and Project Profile Tab Data Organizational leadership/staffing
question

New question regarding organizational staff and
governance. (Optional and not to be used in grant making
decisions or panel review.)

NEPA/NHPA Question Form - 3c
Public Art

New bullet asking for details about temporary art
installations

Accessibility Question Form and
Instructions

Organizational budget

Updates to bullet points outlining types of accommodations
FY24 Challenge America
Simplified - applicants will now be asked to provide income
and expenses for 3 years, but will no longer be asked to
provide detailed breakdowns for each year.

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Project Title
Project Summary

Renamed "Project Synopsis"
Removed from the application

Organizational Partners

New drop down list for applicants to identify project partner
types
Research Awards

GAF questions

Changes to: Mission and Background/History, Org Budget,
Project Summary, Organizational Partners, Project Budget
Instructions, Engagement with Intended Community,
Participants & Audience.
Our Town Grant Application Form (GAF) Instructions

Changes to: Organizational Background, Org Budget, and
Project Partners. Added short-term and long-term systems
Instructions Text
change questions
FY24 Grants for Arts Projects (GAP) Application Instructions (GAF)
For the purposes of PRA review, we have moved the
discipline specific sections to their own standalone
Discipline-specific sections
(Additional Items, Items to Upload)
document.
All Disciplines - Year Founded
New item
All Disciplines - Organizational
Context for Project Activities

Revamped item, used to be Organizational Background

All Disciplines - Organizational
budget

Simplified - applicants will now be asked to provide income
and expenses for 3 years, but will no longer be asked to
provide detailed breakdowns for each year.

All Disciplines - Arts Programmatic
History
All Disciplines - Project Title
All Disciplines - Project Summary
All Disciplines - Project Description
All Disciplines - Key
Individuals/Orgs

Refreshed language, guidance to provide 1-3 examples
Renamed "Project Synopsis"
Removed from the application
Refreshed language
Removal of summary questions

All Disciplines - Key
Individuals/Orgs

Removal of pop-up window, applicants will now have a set
of fields/drop downs for each individual or organization they
enter.

All Disciplines - Organizational
Partners

New drop down list for applicants to identify project partner
types

All Disciplines - Engagement with
Intended Community, Participants &
Audience

Refreshed language; Addition of "race" to "ethnicity"

All Disciplines - Other Project
Information
GAP Design Instructions - Work
Samples

New question
Reduced time to 10 minutes

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GAP Design Instructions Additional Items
GAP Musical Theater Instructions Additional Items
GAP PMW Instructions - Additional
Items
GAP PMW Instructions - Work
Samples
GAP Theater Instructions Additional Items

12

Removed additional items
Removed Artist Statement
Removed Leadership Statement
Revised max images, max pages of documents.
Remove Artist Statement
Government Agencies

State Arts Agency (SAA)
Partnership Application Instructions

Streamlined On and Off year instructions; changes to Plan
Implementation and Accomplishments; Program Budget
Allocations, NEA Related program areas, Poetry out Loud.

Regional Arts Organizations
(RAOs) Partnership Application
Instructions

Streamlined On and Off year instructions; changes to Plan
Implementation and Accomplishments; Program Budget
Allocations, NEA Related program areas.

National Services Partnership
Application Instructions

Streamlined On and Off year instructions, changes to Plan
Implementation and Accomplishments, Resource
Development and Management.
Individuals

Heritage Fellows Acceptance Form
Biographical info

Added “Tribal Affiliation” (Optional, and if applicable)