CHALLENGE AMERICA: Responsible Conduct of Performance Measurement, Program Evaluation, and Research

If you are recommended for a grant and your project includes program evaluation and/or research activities that involve directly collecting information from program participants, the National Endowment for the Arts may conduct a review of your project to ensure that it is in compliance with our general guidance regarding the responsible conduct of research.

Data collection activities conducted under an award are the sole responsibility of the recipient organization, and the National Endowment for the Arts’ support of the project does not constitute approval of those data collection procedures. As such, data collected from respondents/participants will be conducted by the awardee or at the awardee’s direction, and any Arts Endowment-funded researchers collecting data from respondents/participants may not represent to those subjects that such data are being collected on behalf of the National Endowment for the Arts.

Many projects under the Challenge America program include some form of informal evaluation, such as conducting anonymous audience/program satisfaction surveys or basic field observations of program participants, such as counting the number of audience members or tickets sold. Furthermore, informal as well as formal evaluation activities may be done under the rules and regulations governing a school or school district, for programs that occur within schools or school districts. These types of activities are typically exempt from a research ethics review.

However, some grantees want to conduct more formal evaluation research as part of their grant, which may garner a research ethics review. Examples include evaluation activities that include asking program participants to provide sensitive and/or identifying information about themselves, and/or involve systematic studies to assess the program’s benefits for participants.

As an agency, we are committed to the responsible conduct of research. The agency requires applicants to comply with all applicable laws and regulations governing the conduct of research in the United States for projects supported with Arts Endowment funding.

If you are recommended for an award which may require a research ethics review, you will be notified and asked to provide additional information. This may include providing more detail on the purpose and nature of the evaluation activities, when data will be collected for the evaluation activities, the source of the funding to support those evaluation activities, the steps taken to comply with applicable laws and regulations, steps taken to obtain permissions (including but not limited to the acquisition of existing data) from all appropriate entities or individuals (including but not limited to minors or other sensitive populations) for conducting the proposed evaluation activities, and evidence of ethics training in the conduct of human subjects research. Costs of submitting research proposals to Institutional Review Boards (IRBs) are allowable if this activity takes place during the award period of performance; however, the grantee must include evidence that the applicant has consulted with their preferred IRB or IRBs. If you receive an award, we may withhold funds until IRB approval is demonstrated. Evidence of ethics training in the conduct of human subjects research can take the form of an active, unexpired certificate of completion of a training module. The Arts Endowment does not specify or endorse any specific educational programs. The National Endowment for the Arts will not reimburse costs for ethics training.

The U.S. Department of Health and Human Services provides additional guidance and resources for learning about the responsible conduct of research, including a database of registered IRBs; the National Science Foundation also has resources related to IRB and human subjects protections.

Additional information for regarding systematic evaluation studies can be found here:

A research ethics review and approval process may take up to several months to complete and may delay your project's start date and our ability to make a grant award/our ability to release grant funds. Thorough and complete information for all project activities will expedite the review. The Arts Endowment cannot release an award and/or grant funds until the research ethics review is complete.