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

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 NEA may conduct a review of your project to ensure that it complies 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. The NEA’s support of the project does not constitute approval of those data collection procedures. Accordingly, data collected from respondents/participants will be conducted by the awardee or at the awardee’s direction, and any NEA-funded researchers collecting data from respondents/participants may not represent to those subjects that such data are being collected on behalf of the NEA.

Many projects under the Grants for Arts Projects program include some type of informal evaluation, such as conducting anonymized surveys of audiences about their satisfaction with a program, or even basic field observations of program participants such as counting the number of audience members or tickets sold. These types of activities are often exempt from a program evaluation ethics review. Furthermore, data collection activities related to completion of the Final Descriptive Report (FDR) are exempt from a program evaluation ethics review. Examples of questions on the FDR are available here.

Whether formal or informal, however, evaluation activities of arts programs occurring within schools or school districts must be done under the rules and regulations governing those institutions or jurisdictions.

On the other hand, some grantees want to conduct more formal program evaluation and/or research as part of their grant. Program evaluation may require an ethics review, especially if the activities will be completed during the grant’s period of performance and will use funding from the grant or its match (if applicable). Examples include activities that require asking program participants to provide sensitive and/or confidential information about themselves, and/or that involve systematic studies to assess a program’s benefits for participants.

If you are recommended for an award that may require a program evaluation ethics review, you will be notified and asked to provide additional information. This may include providing more detail on such factors as: the purpose and nature of any research or evaluation activities; when data will be collected for these purposes; the source of funding to support these 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 the activity occurs during the award’s period of performance; however, the grantee must provide evidence that the applicant has consulted with its preferred IRB or IRBs. If you receive an award, we may withhold funds until IRB approval is demonstrated and evidence of ethics training in the conduct of human subject’s research is provided for all individuals engaged in research activities that include human subjects. Such evidence can take the form of an active, unexpired certificate of completion of a training module. The NEA does not specify or endorse any specific educational programs. The NEA 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 decision charts for assessing whether a project needs an ethics review, a set of free training modules (which can be used to provide evidence of ethics training for an NEA application), and a database of registered IRBs. The National Science Foundation and the U.S. Department of Education also have resources related to IRB and human subjects’ protections.
Additional information for regarding systematic evaluation studies can be found here: https://www.arts.gov/impact/research/resources-program-evaluation-and-performance-measurement.

A program evaluation review and approval process may take up to several months to complete and may delay your project's start date and the NEA’s ability to make a grant award or the ability to release award funds. Thorough and complete information for all project activities will expedite our process for approving the release of funds. The NEA may withhold award funds until the program evaluation review is complete.