Supporting Statement Part A_Regional and State Arts Agency ARP Funding Survey_v2FINAL

Supporting Statement for the Regional and
State Arts Agency ARP Funding Survey, Part A
Last updated: August 22, 2022

1

Table of Contents
Abstract…………………………………………………………………………………….3
A1. Circumstances that make the collection of information necessary……………..4
A2. Purpose and use of the information.................................................................. 6
A3. Use of information technology and burden reduction. ..................................... 7
A4. Efforts to identify duplication. ........................................................................... 8
A5. Impacts on small businesses or other small entities ........................................ 8
A6. Consequences of collecting the information less frequently ............................ 8
A7. Special circumstances relating to the Guidelines of 5 CFR 1320.6. ................ 9
A8. Comments in response to the Federal Register Notice and efforts to consult
outside Agency…………………………………………………………………………….9
A9. Explain any decisions to provide any payment or gift to respondents ............. 9
A10. Assurances of confidentiality provided to respondents……………………… 10
A11. Justification for any questions of a sensitive nature .....................................10
A12. Estimates of the hour burden of the collection of information. ......................10
A13. Estimates of other total annual cost burden. ................................................11
A14. Provide estimates of annualized costs to the Federal Government ..............11
A15. Explain the reasons for any program changes or adjustments reported on
the burden worksheet…………………………………………………………………...11
A16. Plans for tabulation, and publication and project time schedule ...................12
A17. Displaying the OMB Approval Expiration Date ..............................................13
A18. Exceptions to the certification statement identified in Item 19 ......................12
Table of Attachments
Attachment A: Communication Materials
Attachment B: Web Survey Instrument
Attachment C: Cognitive Testing Report

2

Abstract
This request for regular clearance will enable the National Assembly of State Arts
Agencies (NASAA), in partnership with the National Endowment for the Arts (NEA), to
implement an online survey that will be used to support reporting on the outcomes of relief
funding provided by the American Rescue Plan (ARP) to state-level subgrantees from the
NEA. This package requests the Office of Management and Budget’s (OMB) regular
clearance for one-time data collection.
As part of the stimulus package passed by Congress in March 2021, the ARP
appropriated $135 million to the NEA for emergency relief. Forty percent of these funds
were directed to state arts agencies and regional arts organizations to be distributed for
grantmaking. Stemming from an effort to understand the benefits and outcomes of relief
funds going to states and jurisdictions, the NEA will partner with NASAA to survey
regional arts organizations and state arts agencies to collect data on the how the
subgrantees used NEA ARP funding.
The ARP funding survey is modeled after the Coronavirus Aid, Relief, and
Economic Security Act (CARES Act) funding survey approved by OMB under the same
OMB Control Number (see ICR Ref. No. 202105-3135-001) and administered by the NEA
in partnership with NASAA in 2020. The intent of both surveys is to assess how federal
Covid-19 relief funding from the NEA supported the continuation or creation of jobs and
supported investment in infrastructure for state and regional subgrantees. It captures how
many jobs grantees were able to maintain or create and the dollar amount invested in
facilities. Additionally, it collects any other data state arts agencies are gathering related to
ARP funds. The administration of the survey will allow the NEA to again report on the
outcomes of the relief funds that were distributed to states. The two surveys are identical
3

with the exception that programmatic information regarding relief dollars, like grant
program name and description, is updated in the ARP funding survey.
The online survey will be delivered to 62 state arts agencies and regional arts
organizations who received NEA ARP funding. It will take approximately 4.5 hours per
response with 15 questions and skip patterns built into the survey.
Part A. Justification
A1. 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 NEA is compelled by Congress to obligate 40 percent of its program budget to
state arts agencies and regional arts organizations through Partnership Agreements (20
U.S.C. § 954(g)). In turn, state arts agencies use these funds to support state and
regional grantmaking and other programming, “developing projects and productions in the
arts in such a manner as will furnish adequate programs, facilities, and services in the arts
to all the people and communities in each of the several States.” (20 U.S.C. § 954. (g)(1)).
Like CARES Act funds, ARP funds were administered to state arts agencies and regional
arts organizations via amendments to their already existing fiscal year 2021 partnership
agreements, which are reported to the NEA annually in Final Descriptive Reports (OMB
Control Number 3135-0140).
However, the NEA’s Final Descriptive Reports for state arts agencies and regional
arts organizations do not request data describing the jobs and facility or infrastructure
investments, which were the primary purpose of ARP dollars to state arts agencies and
regional arts organizations. The planned data collection is a new information request as
4

the subgrantee data are not available elsewhere unless obtained through this information
collection.
For CARES Act funding, NASAA gathered data to determine the appropriate
mechanism for collecting data on the effects of CARES Act funding going to state arts
agencies. First, NASAA convened a listening session on June 24, 2020, with 9 executive
directors of state arts agencies and regional arts organizations to discuss the burden of
reporting requirements associated with CARES Act funding. Based on the listening
session, the NEA determined there would be no reporting requirements to mitigate
additional burden. Instead there was potential for a survey of subgrantees, or a survey of
state arts agencies and regional arts organizations based on data they collected from
subgrantees, to capture jobs and facility costs. To that end, in December 2020 and
January 2021, NASAA gathered information (from a conversation with grants officers and
individual states’ reviewing reporting requirements) on what data state arts agencies have
collected from subgrantees. NASAA also had a conversation with grants officers to
ascertain the same information. It was determined that the least amount of burden would
be to survey state art agencies and regional arts organizations to collect estimates of
CARES Act funds on subgrantees. Based on this information, the NEA seeks to again
reduce burden on subgrantees when collecting information about ARP funds by
administering a survey.
Aligned with this previous work on CARES Act funding, a survey will once again be
employed to gather information about the impact of NEA Covid-19 relief funding that is not
available otherwise. The online ARP funding survey of state arts agencies and regional
arts organizations will be implemented once in winter 2023 and will gather data on the
outputs and outcomes of grantmaking using ARP funds distributed by the NEA.
5

Knowledge gained through this information collection will enable the NEA to collect
evidence on the effect of ARP funding administered to mitigate the adverse economic
impacts of the COVID-19 pandemic.
A2. Purpose and use of the information.
Indicate how, by whom, and for what purpose the information is to be used. Except
for a new collection, indicate how the agency has actually used the information
received from the current collection.
NASAA, in partnership with the NEA, will issue one survey to each of the 62 states,
jurisdictions and regions to estimate how grantees and subgrantees benefited from the
ARP funding administered by the NEA. The survey will be administered via an online
platform to executive directors or deputy directors of 62 state arts agencies and regional
arts organizations. The NEA will use the information collected in the survey to report on
how emergency relief has served communities across the U.S. The survey will ask the
following information from each state arts agency and regional arts organization:
•

Detail how the state or region administered NEA ARP funding.

•

Estimate how many jobs subgrantees were able to maintain or create due to
NEA ARP dollars.

•

Estimate the total dollar amount subgrantees invested in facilities and
infrastructure and the number of organizations receiving facilities and
infrastructure grants due to NEA ARP dollars.

•

Provide an opportunity to share any additional qualitative or quantitative
subgrantee data related to NEA ARP funding that state arts agencies and
regional arts organizations have collected.

•

Select specific benefits the NEA ARP funding has had in the state or region.

NASAA will report data for individual states, regions, and jurisdictions to the NEA
6

and will conduct an analysis to determine what can be reported or extrapolated in the
aggregate based on available data. The research project will culminate with a report of
findings prepared by NASAA.
The NEA will include aggregated subgrantee data as part of overall ARP public
reporting. The primary indicators will be the number of jobs created or maintained by
grantees and subgrantees (full-time and part-time), and the infrastructure supported with
ARP dollars.
A3. Use of information technology and burden reduction.
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.
NASAA and the NEA take their responsibility to minimize burden on respondents
very seriously and has designed this project with that goal in mind. By designing an online
survey, NASAA eliminated hundreds of hours of labor that would have been required to
administer a paper-based survey. An online survey enables the surveying of all state arts
agencies at no additional cost. Thus, the electronic nature of the survey provides the most
efficient mechanism for NASAA to capture responses from these state agencies and
regional organizations.
Once the survey is electronically deployed, it will include dynamic survey logic that
will tailor the questions to present the most applicable and relevant questions to
respondents. For example, those who respond no to a question asking if they have data
on subgrantee job creation, they will not be shown any follow up questions related to how
many jobs subgrantees created.
7

A4. Efforts to identify duplication.
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.
There is no similar ongoing data collection being conducted that duplicates the
efforts of the proposed data collection. The online survey is the first and only federal and
aggregated survey on NEA ARP funding outcomes at the subgrantee level. As a result,
the NEA lacks information about outcome of ARP funding at the subgrantee level.
A5. Impacts on small businesses or other small entities.
No small business entities or other small entities are involved in this data collection.
By opting to survey 56 state arts agencies, which are state government entities, and 6
regional arts organizations, instead of subgrantees, this has eliminated burden or impacts
on hundreds of small entities.
A6. Consequences of collecting the information less frequently.
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 the burden.
Without this survey, the NEA would have no method for capturing the specifically
identified outcomes of importance from the 40 percent of the NEA ARP funding that were
allocated to state arts agencies and regional arts organizations.
Like CARES Act funding, state arts agencies will track subgrant recipients and
dollar amounts associated with each subgrantee for ARP funding based on direction
from OMB that no new reporting requirements should be associated with relief funding.
State arts agencies and regional arts organizations will report total funding amounts
within their regular, annual Final Descriptive Reports to the NEA. However, these
8

standard data requirements do not require specific disaggregated data for individual ARP
dollars. SAAs and RAOs administered ARP dollars through a variety of mechanisms
including current grantee amendments and new grant programs.
Additionally, these standard reporting requirements do not contain data on the
primary purposes of ARP funding as administered via the NEA: to retain jobs and
operation of facilities during the COVID-19 crises. Without these data, the NEA will not
have sufficient information to understand the outcomes of ARP relief policies. Due to the
unprecedented financial impact of the COVID-19 pandemic, and the subsequent
stimulus, this was an unforeseen supplemental funding stream and will not be a regularly
occurring funding stream in the future.
A7. Special circumstances relating to the Guidelines of 5 CFR 1320.6.
The information will be collected in a manner consistent with the guidelines in 5
CFR 1320.6 (Controlling Paperwork Burden on the Public-General Information Collection
Guidelines). There are no special circumstances contrary to these guidelines.
A8. Comments in response to the Federal Register Notice and efforts to consult
outside Agency.
On June 17, 2022, a 60-day Federal Register Notice was published in 87 FR 36546
Volume 87, No. 117. One comment was received. Cognitive testing of the web survey
developed for the CARES Act Funding Survey, which the Regional and State ARP
Funding Survey is based on, was conducted in March 2021, with eight state respondents,
and feedback from one regional arts organization in May 2021. See Attachment C. On
August 22, 2022 a 30-day Federal Register Notice was published in Volume 87 FR 51453
Volume 87, No. 161.
A9. Explain any decisions to provide any payment or gift to respondents

9

Respondents will not receive any payment or gifts for completion of the web survey.
A10. Assurances of confidentiality provided to respondents.
The survey introduction and email communications include a statement to
respondents that all data for the survey will be kept confidential and that data will only be
analyzed and reported to the public in aggregate. NASAA will provide all respondents with
a description of the importance of the survey and a notification that their response to the
survey is voluntary. The NEA will include aggregated subgrantee data as part of overall
ARP reporting.
A11. Justification for any questions of a sensitive nature.
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.
The survey does not contain any questions of a sensitive nature.
A12. Estimates of the hour burden of the collection of information.
Provide estimates of the hour burden of the collection of information. Indicate the
number of respondents, frequency of response, annual hour burden, and an
explanation of how the burden was estimated.
Participant
Description

Instrument Average
or Activity Hours per
Response

State arts
agencies and
regional arts
organizations

Web Survey

4.5

Number of
Responses
per Person
1

Total

Estimated
Burden
Responses (Hours)
62

279

The total estimated burden for online surveys to be conducted in winter 2023 is
16,740 minutes, or 279 hours, based on the estimate of 4.5 hours per respondent, as
supported by the findings from the cognitive testing of the CARES Act funding survey

10

instrument, which the Regional and State ARP Funding Survey is based on. Participants
reported the survey took 29.4 minutes, on average, to complete, with a range of 5 to 90
minutes. Those who reported longer times said they needed to consult with colleagues
and/or extract data. Those who reported shorter times acknowledged that it would take
longer to complete the survey when they had all of their data to report. All participants
reported that additional time will be needed to extract information from spreadsheets,
applications, and/or final reports. Time estimates for extracting and compiling this data
ranged from 2 to 35 hours. The higher end of the time estimation was due to some
respondents having to extract quantitative data from individual qualitative reports. Instead
of placing burden on the respondent to extract these data, the survey allows for them to
upload raw data, if convenient.
A13. Estimates of other total annual cost burden.
Provide an estimate for the total annual cost burden to respondents or
recordkeepers resulting from the collection of information.
The estimated total annual cost burden is $9,575.28. This is based on the above
figure of 4.5 hours of respondent burden multiplied by $34.32, which is the average hourly
wages and salaries of state and local government employees1.
A14. Provide estimates of annualized costs to the Federal Government.
The total one-time contracted cost to the Federal Government is $25,000 for
NASAA staff hours and all other outside professional services.
A15. Explain the reasons for any program changes or adjustments reported on the
burden worksheet.
The survey is a new data collection.
U.S. Bureau of Labor Statistics (2022), Employer Costs for Employee Compensation - March 2022.
https://www.bls.gov/news.release/pdf/ecec.pdf.
1

11

A16. Plans for tabulation, and publication and project time schedule.
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 purpose of this clearance package is to obtain full clearance for the NEA and
NASAA to conduct data collection from state arts agencies and regional arts
organizations. NASAA conducted preliminary conversations with state arts agency grants
officers and review of Covid-19 relief funding reporting materials in December 2020 and
January 2021 during the development phase for the CARES Act Funding Survey, which
the Regional and State ARP Funding Survey is based on. After obtaining final clearance
for the Regional and State ARP Funding Survey, NASAA will conduct one survey in winter
2023, pending OMB approval, with a report to be delivered to the NEA in March 2023. A
descriptive statistical analysis will be used to examine aggregate survey data. A final
report will estimate the total number of jobs created or retained and the amount granted
for infrastructure. NASAA will also clean and evaluate additional raw data uploaded by
respondents and will assess benefits of NEA ARP funding to states and regions,
describing variation in response through cross tabulations.
A17. Displaying the OMB Approval Expiration Date.
If you are seeking approval to not display the expiration date for OMB approval of
the information collection, explain the reasons that display would be inappropriate.
NASAA and the NEA will display the expiration date of OMB approval and the OMB
approval number on all instruments associated with this information collection, including
forms and questionnaires.
A18. Exceptions to the certification statement identified in Item 19.

12

Explain each exception to the topics of the certification statement identified in
Certification for Paperwork Reduction Act Submissions.
No exceptions are necessary for this information collection.

13