OUR TOWN: Place-Based Projects - Award Administration

These are expired guidelines. New guidelines will be posted in May, 2019.

National Environmental Policy Act and/or the National Historic Preservation Act Review

If you are recommended for a grant and your project may be subject to the National Environmental Policy Act  (NEPA) and/or the National Historic Preservation Act (NHPA), the National Endowment for the Arts will conduct a review of your project to ensure that it is in compliance with NEPA/NHPA.

Some of the common project types that garner a NHPA review are:

  • A project involving or occurring near a district, site, building, landscape, structure or object that is at least 50 years old or older and therefore included in or eligible for inclusion in the National Register of Historic Places (please note that in some instances, buildings or structures may be included in or eligible for inclusion in the National Register of Historic Places that are less than 50 years old).
  • The commissioning and installation of temporary or permanent outdoor furnishings such as benches or market structures or art such as a sculpture or mural.
  • An arts festival in a park.
  • Design planning and services for projects that may involve a historic site, structure, or district.

This review and approval process may take up to several months to complete and may delay your project's start date. The results of the review may impact our ability to make a grant award/our ability to release grant funds. If you are recommended for an award which may have historic preservation or environmental concerns (NHPA/NEPA), you will be notified and asked to provide additional information. Your thorough and complete information for all project activities and locations will expedite the review. The NEA cannot release an award and/or grant funds until the historic preservation and environmental review is complete.

To learn more about what questions you will need to answer for the review of a project impacted by the National Environmental Policy Act and/or the National Historic Preservation Act, see here.


Federal regulations require that all NEA-funded projects be accessible to people with disabilities. Funded activities must be held in an accessible venue and program access and effective communication must be provided for participants and audience members with disabilities. If your project is recommended for funding, you will be asked to provide information describing how you will make your project physically and programmatically accessible to people with disabilities:

  • Buildings and facilities (including projects held in historic facilities), should be physically accessible. This includes, but is not limited to: ground-level entry, ramped access, and/or elevators to the venue; integrated and dispersed wheelchair seating in assembly areas; wheelchair-accessible box office, stage, and dressing rooms; wheelchair-accessible display cases, exhibit areas, and counters; and wheelchair-accessible restrooms and water fountains.
  • The programmatic offering should be accessible either as part of the funded activity or upon request, where relevant. This can include, but is not limited to: contact information for requesting accommodations; electronic materials and websites; print materials in alternative formats, such as large-print brochures/labels, Braille, and electronic/digital formats; accommodations for performance, tours, and lectures, such as audio description, tactile opportunities, sign language interpretation, and real-time captioning; closed/open captioning of video and film; and assistive listening devices.

Please see the Nondiscrimination Statutes in our "Assurance of Compliance" for additional information. For technical assistance on how to make your project fully accessible, contact the Accessibility Office at accessibility@arts.gov, 202/682-5532 Voice or the Civil Rights Office at 202/682-5454 or 202/682-5082 Voice/T.T.Y., or see our online Accessibility Resources.

Changes in Projects

Applicants must notify the National Endowment for the Arts immediately of any significant changes in their project that occur after they have submitted their application. If the project or the organization's capacity changes significantly before an award is made, any funding recommendation may be revised or withdrawn.

Grantees are expected to carry out a project that is consistent with the proposal that was approved for funding by the National Endowment for the Arts. If changes in the project are believed to be necessary, the grantee must send a written request, with justification, to the Grants & Contracts Office prior to the expenditure of grant funds. Approval is not guaranteed. Detailed information is included the NEA General Terms & Conditions for Grants to Organizations.

Project Reporting and Evaluation

We ask all applicants to define what they would like to achieve, how they will evaluate the degree to which it is achieved, and, upon completion of the project, what they have learned from their experiences. Such feedback need not entail large-scale or expensive evaluation efforts. You should do what is feasible and appropriate for your organization and project. When a grant is completed, you must submit a final report and answer questions on your achievements and how these were determined. We recognize that some projects involve risk, and we want to hear about both your successes and failures. Failures can provide valuable learning experiences, and reporting them will have no effect on your ability to receive NEA funds in the future.

All Our Town grantees will be assigned the agency's Strengthening Communities objective. Before applying, please review the reporting requirements for the agency's Strengthening Communities objective. Given the nature of Strengthening Communities projects, benefits are likely to emerge over time and may not be fully measureable during the period of a grant. You will need to provide evidence of progress toward achieving improved strengthening of the community(ies) as appropriate to the project.

Crediting Requirement

Grantees must clearly acknowledge support from the National Endowment for the Arts in their programs and related promotional material including publications and websites. Additional acknowledgment requirements may be provided later.

Administrative Requirements

Beyond the reporting requirements for all grantees, selected Our Town grantees may be asked to assist in the collection of additional information that can help the National Endowment for the Arts determine the degree to which agency objectives were achieved. For example, Our Town grantees may be asked to participate in surveys or interviews, and/or may be asked to assist in publicizing and promoting these data collection efforts. You may be contacted to provide evidence of project accomplishments including, but not limited to, work samples, community action plans, cultural asset studies, programs, reviews, relevant news clippings, and playbills. Please remember that you are required to maintain project documentation for three years following submission of your final report.

We may publish grantees' reports and products on our website. Please note that all federal grantmaking agencies retain a royalty-free right to use all or a portion of grantees' reports and products for federal purposes.

Award Notices

Grant decisions for the Our Town category are expected to be announced in April 2019.

Note that "announcement" is likely to take the form of a preliminary congratulatory note, a request for revisions, or a rejection notification. Official grant award notification (i.e., a notice of action authorized by the National Endowment for the Arts Grants & Contracts Office) is the only legal and valid confirmation of award. This can take several months depending on a number of factors such as whether a revised budget is needed for your project, the number ofawards to be processed, whether the agency has its appropriation from Congress, etc.

Implementation of Title 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards

This guidance from the federal government's Office of Management and Budget (OMB) establishes clarity and consistency of the pre- and post-award requirements applicable to federal grantees. Under the authority listed above, the National Endowment for the Arts adopts the Office of Management and Budget (OMB) Guidance in 2 CFR part 200 under §3255.1 Adoption of 2 CFR Part 200. This part gives regulatory effect to the OMB guidance and supplements the guidance as needed for the National Endowment for the Arts. 

General Terms & Conditions

Federal and agency requirements that relate to grants awarded by the National Endowment for the Arts are highlighted in our General Terms & Conditions (GTC). The GTC incorporates the adoption of 2 CFR Part 200 by reference. The document also explicitly identifies where the National Endowment for the Arts has selected options offered in the regulation, such as budget waivers and requirements for use of program income. It also includes agency requirements for matching funds reporting requirements, amendment processes, and termination actions. Grantees must review, understand, and comply with these requirements. Failure to do so may result in having a grant terminated and/or returning funds to the National Endowment for the Arts, among other things.  

Legal Requirements: 

PLEASE NOTE: This list highlights some of the significant legal requirements that may apply to an applicant or grantee however, it is not exhaustive.   More information regarding these and other legal requirements may be found at Appendix A of our General Terms & Conditions (GTC) which sets forth the National Policy and Other Legal Requirements, Statutes, and Regulations that Govern Your Award. Please note that there may be other applicable legal requirements that are not listed here.

  1. By law, the National Endowment for the Arts may support only those organizations that:

    • Are tax-exempt. Organizations qualifying for this status must meet the following criteria:

      1. No part of net earnings may benefit a private stockholder or individual.
      2. Donations to the organization must be allowable as a charitable contribution under Section 170(c) of the Internal Revenue Code of 1954, as amended.

      For further information, go to the Internal Revenue Service's (IRS) website.

      Note that organizations who have had their IRS status revoked are not eligible for National Endowment for the Arts support. It is your responsibility to ensure that your status is current at the time of the application and throughout the life of your award.

    • Compensate all professional performers and related or supporting professional personnel on National Endowment for the Arts-supported projects at no less than the prevailing minimum compensation. (This requirement is in accordance with regulations that have been issued by the Secretary of Labor in 29 C.F.R. Part 505.  This part does not provide information on specific compensation levels.)

    • Ensure that no part of any National Endowment for the Arts-supported project will be performed or engaged in under working conditions which are unsanitary or hazardous or dangerous to the health and safety of the employees involved.

  2. Some legal requirements apply to every applicant, for example:

    • Compliance with the federal requirements that are outlined in the "Assurance of Compliance" below.

    • Debarment and Suspension procedures. The applicant must comply with the record keeping and other requirements set forth in Subpart C of 2 CFR 180, as adopted by the Arts Endowment in 2 CFR 32.3254.  Failure to comply may result in the debarment or suspension of the grantee and the NEA suspending, terminating and/or recovering funds.

    • Federal Debt Status (OMB Circular A-129).  Processing of applications will be suspended when applicants are delinquent on federal tax or non-tax debts, including judgment liens against property for a debt to the federal government. An organization's debt status is displayed in the System for Award Management (SAM). New awards will not be made if an applicant is still in debt status as of September 1.

    • Labor Standards (29 C.F.R. pt 505).    If a grant is awarded, the grantee must comply with the standards set out in Labor Standards on Projects or Productions Assisted by Grants from the National Endowments for the Arts and Humanities.

    • The Drug-Free Workplace Act of 1988 (41 U.S.C. 701 et seq. and  2 C.F.R. Part 3256).  The grantee is required to publish a statement regarding its drug-free workplace program as well as comply with other requirements.

  3. Some legal requirements apply depending upon what the grant is funding, for example:

    • If your project activities have the potential to impact any structure that is eligible for or on the National Register of Historic Places, adjacent to a structure that is eligible for or on the National Register of Historic Places, or located in an historic district, you will be asked to provide additional information about your project or take additional action so that the agency can review and comply  with the National Historic Preservation Act (NHPA). NHPA also applies to any planning activities that may affect historic properties or districts.  The additional agency review must be completed prior to any agency funds being released.

    • If your project activities have the potential to impact the environment or environmentally sensitive resources, you will be required to provide information in accordance with the National Environmental Policy Act (NEPA). The additional agency review must be completed prior to any agency funds being released.

    • If your contract is over $2,000 and involves the construction, alteration, or repair of public buildings or public works, it must contain a clause setting forth the minimum wages to be paid to laborers and mechanics employed under the contract in accordance with The Davis-Bacon and Related Acts (DBRA)

  4. Some legal requirements apply depending upon who the Applicant is, for example:

    The Native American Graves Protection and Repatriation Act of 1990 (25 U.S.C. 3001 et seq.) – which applies to any organization that controls or possesses Native American human remains and associated funerary objects and receives Federal funding, even for a purpose unrelated to the Act (25 USC 3001 et seq.)

Assurance of Compliance

By signing and submitting its application form on grants.gov, the Applicant certifies that it is in compliance with the statutes outlined below and all related National Endowment for the Arts regulations and will maintain records and submit the reports that are necessary to determine compliance.

The Arts Endowment may conduct a review of your organization to ensure that it is in compliance. If the Endowment determines that a grantee has failed to comply with these statutes, it may suspend, terminate, and/or recover funds. This assurance is subject to judicial enforcement.

The Applicant certifies that it does not discriminate:

  • On the grounds of race, color, or national origin, in accordance with Title VI of the Civil Rights Act of 1964, as amended (42 U.S.C. 2000d et seq.), implemented by the NEA at 45 U.S.C.1110;

  • On the grounds of disability, in accordance with Section 504 of the Rehabilitation Act of 1973 (29 U.S.C. 794) and the Americans with Disabilities Act of 1990 ("ADA"), as amended, (42 U.S.C. 12101-12213), implemented by the NEA at 45 U.S.C. 1151. The ADA's requirements apply regardless of whether you receive federal funds.

  • On the basis of age, in accordance with the Age Discrimination Act of 1975 (42 U.S.C. 6101 et seq.) implemented by the NEA at 45 U.S.C.1156.

  • On the basis of sex, in any education program or activity, in accordance with Title IX of the Education Amendments of 1972 (20 U.S.C. 1681 et seq.).

Applicant will inform the public that persons who believe they have been discriminated against on the basis of race, color, national origin, disability, sex, or age may file a complaint with the Director of Civil Rights at the NEA.

Applicant will forward all complaints for investigation and any finding issued by a Federal or state court or by a Federal or state administrative agency to:

Director, Office of Civil Rights
National Endowment for the Arts
400 7th Street, SW
Washington, DC 20506

Applicant shall maintain records of its compliance and submission for three (3) years.  The Applicant will compile, maintain and permit access to records as required by applicable regulations, guidelines or other directives.

The Applicant must also certify that it will obtain assurances of compliance from all subrecipients and will require all subrecipients of NEA funds to comply with these requirements.  

The United States has the right to seek judicial or administrative enforcement of this assurance.

For further information and copies of the nondiscrimination regulations identified above, please contact the Office of Civil Rights at 202/682-5454 or 202/682-5082 Voice/T.T.Y. For inquiries about limited English proficiency, please go to http://www.lep.gov, the FOIA Reading Room, or contact the Office of General Counsel at GeneralCounsel@arts.gov or 202/682-5418.