Indemnity Supporting Statement A Final

National Endowment for the Arts Application for International and Domestic Indemnification
Supporting Statement
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.
This form is used by organizations applying to the Federal Council on the Arts and the
Humanities (through the National Endowment for the Arts) for indemnification of eligible
arts and artifacts. Applicants for International Indemnity apply for eligible arts and
artifacts borrowed from abroad for exhibition in the United States, from within the
United States when the foreign works of art are integral to the exhibition, or sent from
the United States for exhibition abroad. Applicants for the Domestic Indemnity apply for
eligible arts and artifacts borrowed from the United States for exhibition in the United
States. The indemnity agreement is backed by the full faith and credit of the United
States. In the event of loss or damage to an indemnified object the Federal Council
certifies the validity of the claim and requests payment from Congress. The Arts and
Artifacts Indemnity Act (P.L. 94-158) requires such an application and specifies
information which must be supplied. This statutory requirement is implemented by
regulation at 45 C.F.R. 1160.4.
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.
Applicants are non-profit entities, usually museums that organize traveling exhibitions.
Applications are reviewed by the Indemnity Advisory Panel and the Federal Council on the
Arts and the Humanities to determine whether to issue a Certificate of Indemnity.
Applications are necessary in making that decision.
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.
Information about Indemnity, including how to apply for coverage, is available on the Arts
Endowment’s website. The website provides a direct link to the application package on
Grants.gov and NEA Applicant Portal. Applicants are asked to submit their application
packages electronically through Grants.gov (SF-424) and NEA Applicant Portal (all
materials).
4. Describe efforts to identify duplication. Show specifically why any similar information
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National Endowment for the Arts Application for International and Domestic Indemnification
Supporting Statement
already available cannot be used or modified for use for the purposes described in
Item 2 above.
This information is not reported through any other sources. Applicants apply for a single,
specific exhibition to be indemnified.
5. If the collection of information impacts small businesses or other small entities,
describe any methods used to minimize burden.
Museums that organize exhibitions with lent objects are not small entities.
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 application for indemnity is a one-time submission which an applicant makes prior to
an exhibition. It could not be made less frequently.
7. Explain any specific 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.
None.
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
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National Endowment for the Arts Application for International and Domestic Indemnification
Supporting Statement
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.
Notice for comment was published in the Federal Register. No comments were received.
The members of the Advisory Panel and the Federal Council are consulted quarterly, to
obtain their views and incorporate their recommendations for changes in the application
and instructions.
9. Explain any decision to provide any payment or gift to respondents, other than
remuneration of contractors or grantees.
Not applicable.
10. Describe any assurance of confidentiality provided to respondents and the basis for
the assurance in statute, regulation, or agency policy.
No assurance of confidentiality is provided.
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.
This application does not contain questions of a sensitive nature such as matters
concerning sexual behavior and attitudes, religious beliefs, and other matters commonly
considered private.
12. Provide estimates of the hour burden of the collection of information. The statement
should:
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National Endowment for the Arts Application for International and Domestic Indemnification
Supporting Statement
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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 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 in Item 13.
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
13.

An estimated 10 respondents per year apply for the for Domestic Indemnity, and 15 for
International Indemnity. It is estimated that each respondent for Domestic Indemnity
spends an average of 50 hours completing this form, and each respondent for
International Indemnity spends an average of 55 hours completing this form. The
application for indemnification is a one-time submission. No additional form is required.
Although the costs to respondents vary depending upon the complexity of the exhibition,
i.e., the number of objects in the exhibition, the number of lenders, and the number of
exhibition sites, it is estimated that the average cost to respondents is $1,590. This
estimated cost includes respondent time between professional staff and support staff for
each applicant. The cost burden and COLA for this information collection was based on
average salaries for curators and registrars (the positions of applicants who generally will
be completing the Indemnity Application) from art museums.
13. Provide an estimate for 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).
• The cost estimate should be split into two components: (a) a total capital and startup 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
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National Endowment for the Arts Application for International and Domestic Indemnification
Supporting Statement
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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 collections 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.

None.
14. Provide estimates of annualized costs 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, overhead, 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.
The estimated cost of this Program to the Government is $270,507 annually, which
includes staff salaries, printing and mailing of written material, and, infrequently, the
need to pay for the services of an insurance adjustor.
15. Explain the reasons for any program changes or adjustments reported in Items 13 or
14 of the ICR.
None.
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.
There are no plans to publish collections of information for statistical use.
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.
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National Endowment for the Arts Application for International and Domestic Indemnification
Supporting Statement
Not applicable.
18. Explain each exception to the certification statement identified in Item 19,
"Certification for Paperwork Reduction Act Submissions.”
Not applicable.
Addendum: 2026 PRA Summary of Changes to Application Guidelines and Requirements
Section

Indemnity landing page
Applicant & Object Eligibility

Introduction

Uploaded Items
Instructions
Instructions
Visual Documentation

Change
Domestic & International landing pages
combined to reduce repetition of duplicative
langauge. Easier for applicants to determine
which program better suits their indemnity
request.
Moved from general landing page to
instructions to provide streamlined guidance.
General notes moved from areas of the
instructions to introduction section to
provide overall context and keep instructions
focused on specific attachment
requirements.
Facility Reports and Floor plans broken out
into their own attachments, rather than
being appended to the Idemnity Narrative.
No increase in requirements.
Formatting updates to better outline
guidance vs. questions applicants need to
address.
Formatting updates for uniformity across
attachments.
Visual documentation instructions broken
out into two sections, rather than being
combined. No increase in requirements.

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