American Rescue Plan Grants to Local Arts Agencies for Subgranting: Award Administration

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. Such acknowledgement should clearly indicate that funds were provided for general operating support and should not be used to indicate support for a project that the agency has not funded. Additional acknowledgment requirements may be provided later.

Administrative Requirements

Before submitting an application, organizations should review the Administrative Requirements section of the Grants for Arts Projects guidelines (this Rescue Plan funding opportunity has the same Administrative Requirements as the Arts Endowment’s Grants for Arts Projects program) and the General Terms & Conditions for detailed information on legal requirements, financial reviews and audits, and other administrative matters that pertain to this funding opportunity.

In addition to the requirements described above, grantees will be required to report on funding received through this program.

Proper documentation must be maintained for all salaries charged, in whole or in part, to this award per 2 CFR §200.302, .333, .430(I). This includes:

  • Personnel activity (“Time & Effort”) information, which may be established electronically and made available for review, for any employee whose salary is charged, in whole or in part, to the award. OMB Uniform Guidance 2 CFR 200.430 (i)(1) Standards for Documentation of Personnel Expenses requires salary and wage expenses to be based on records that accurately reflect the work performed. The records must be supported by a system of internal controls which provide reasonable assurance that the charges are accurate, allowable, properly allocated and reflect the total activity for which the employee is compensated.
  • For grants that engage artists and/or contractual personnel to whom fees will be paid, maintain written contracts that outline the employment terms.

Subgranting Reporting:

Subgranting applicants that are recommended for funding will have additional reporting requirements as grantees, including but not limited to the below. For a complete understanding of grantee requirements, see the Subgranting Terms and Conditions resource.

  • Require their grantees to provide a Unique Entity Identifier (currently a DUNS) number before a grant can be made.
  • Report subgrants of $35,000 or more in federal funds to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
  • Ensure that all subawards made with federal or cost share/matching funds are in compliance with the General Terms and Conditions for an award from the National Endowment for the Arts, including requirements for pass-through entities as provided for under 2 CFR 200.331 and the NHPA/NEPA and accessibility requirements described below.
  • In accordance with the Arts Endowment's enabling legislation, you must include "artistic excellence and artistic merit" in the review criteria used to make the subgrant awards (20 USC Sec. 951 et seq.).

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

The National Historic Preservation Act of 1966, as amended, applies to any Federal funds that support activities that have the potential to impact any structure 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 a historic district, in accordance with Section 106. This also applies to planning activities that may affect historic properties or districts.

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

For this funding opportunity, NHPA/NEPA review may be necessary if grants support artist fees related to public artwork. The Arts Endowment will identify these items to the extent possible during the pre-award review stage. However, grantees should contact the Office of Grants Management prior to incurring any costs that they believe might require a review for compliance. You may be asked to provide additional information on your project to ensure compliance with the Act at any time during your award period (16 USC 470).


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

Project Reporting and Evaluation

Rescue Plan grantees will be required to report out on activities supported through this program. See detailed information.