NEA Subrecipient FAQs

Please contact the Contracts Office if you have any questions or comments.

NATIONAL ENDOWMENT OF THE ARTS (NEA) SUBRECIPIENT FAQs

New this year: Grantees receiving federal funds or whose awards are counted as match will now receive 100% of their award in a single payment, replacing the previous 80%/20% split payment schedule.

NEA funding helps organizations like yours expand their impact, engage underserved communities, and strengthen the arts across the nation. Because federal funding comes with specific terms and conditions, we’ve created this FAQ to guide you through the requirements and help ensure your success as an NEA subrecipient.

Understanding Your Award

Why is my organization receiving National Endowment for the Arts (NEA) funding when we applied to Mass Cultural Council, a state agency?
Mass Cultural Council receives a Partnership grant from the NEA and subawards a portion of those federal funds to eligible applicants. If your award is funded with NEA dollars, you are considered a subrecipient of federal financial assistance, even though you applied through a state agency.

Does this mean that we are considered a federal contractor?
No. You are not a federal contractor. You are a subrecipient of a federal grant under the Uniform Guidance (2 CFR 200). This means your award is governed by federal grant rules and NEA General Terms and Conditions, not the Federal Acquisition Regulations (FAR) used for procurement contracts.

Can we receive the grant from state funds instead of federal funds?
Mass Cultural Council does not allow grantees to choose the source of their award funding. If your award has been designated as NEA-funded and you have substantial, material concerns regarding your ability to accept or administer federal funds, please submit them in writing to Cathy Cheng-Anderson, Chief Financial Officer, by September 18, 2025.

Getting Started a a Subrecipient

What steps should subrecipients take now?

Review your subaward agreement in detail.
Sign subrecipient notice in the contract package.
Set up internal systems for recordkeeping, reporting, and compliance monitoring.
Train relevant staff on grant requirements.

What can I do now to get ready?

Set up a filing system (digital or paper) for grant records.
Make sure your key staff know about the requirements (see below).
Review your policies on procurement and nondiscrimination.
Check your SAM.gov status, your Unique Entity Identifier (UEI) must stay active and current for the life of the subaward.

Do we need to register in SAM.gov?
Yes. Subrecipients must obtain a Unique Entity Identifier (UEI) from SAM.gov. Your UEI must stay active and current for the life of the subaward.

NEA Terms & Conditions, Civil Rights Compliance

Did the NEA’s general terms and conditions change recently?
Yes, the NEA incorporated updates to the Uniform Guidance (2 CFR Part 200) — which governs federal grant administration — into its own General Terms and Conditions. These updates reflect changes effective as of October 1, 2024, and apply to NEA awards issued on or after that date. See NEA’s General Terms and Conditions.

Are diversity, equity, inclusion, and accessibility (DEIA) programs allowed?
Yes, they are allowed. Under the Federal Fiscal Year 2025 Partnership General Terms and Conditions, programs that include diversity, equity, inclusion, or accessibility (DEIA) goals are not automatically disallowed. In fact, the NEA affirms that many state and regional programs — including those designed to expand access and participation in diverse communities — are fully permissible when they follow federal requirements.

While funding sources may differ, the expectations for grantees remain the same that all programs must comply with applicable laws and civil rights protections. This means activities must be lawful, nondiscriminatory, and consistent with statutes such as Title VI of the Civil Rights Act, Title IX, Section 504 of the Rehabilitation Act, and the Americans with Disabilities Act (ADA). Programs must not use protected characteristics (race, color, national origin, sex, religion, disability, age, etc.) in violation of federal civil rights laws.

We are a culturally specific organization — what does this mean for us?
As a culturally specific organization, you may design and deliver programming that reflects and celebrates your community’s heritage, traditions, and/or lived experiences. This includes offering culturally relevant services, artistic practices, and community-centered programming. However, all participation must remain open to the general public. You cannot restrict or limit access based on race, ethnicity, national origin, religion, gender, disability, age, sexual orientation, or any other protected characteristic under federal or state civil rights laws. In other words, while your mission and programming may center a particular cultural identity or community, your activities must be inclusive, nondiscriminatory, and accessible to anyone who wishes to engage.

Do civil rights laws apply to all my programs or just those receiving NEA funds?
Civil rights laws apply to all of your programs and activities, not only those supported with NEA funds. This means everything you do must be lawful, nondiscriminatory, and consistent with federal and state civil rights requirements, including Title VI of the Civil Rights Act, Title IX, Section 504 of the Rehabilitation Act, and the Americans with Disabilities Act (ADA). Your programs cannot use protected characteristics—such as race, color, national origin, sex, religion, disability, or age in violation of federal civil rights laws.

Compliance & Management

What are the key compliance requirements for subrecipients?
As a subrecipient of federal funds, your organization is responsible for complying with all applicable federal laws, regulations, and award conditions. This includes, but is not limited to, adherence to the NEA General Terms and Conditions for Partnership Agreements, the Uniform Administrative Requirements, Cost Principles, and Audit Requirements under 2 CFR Part 200, the NEA National Policy Requirements, and any applicable Executive Orders.

Is there additional reporting required, and if yes, when is it due?
Yes, grantees are asked to complete a Federal Funds Report in addition to their Final or Annual Report to Mass Cultural Council. The Federal Fund Report can be found in the grantee’s portal in Mass Cultural Council’s Grants Management System. It is simply an attestation and accounting of how the federal funds were spent. The report is due by July 7, 2026. Organizations needing the full grant period (July 1, 2025 – June 30, 2026) to spend and report on the funds can request an extension.

Will the requirements of the federal grant overwhelm my organization?
No, not if you maintain organized records and follow your subaward agreement. Many small nonprofits successfully manage federal subawards each year.

What happens if our project changes?
For organizations receiving grants from YouthReach, Creative Experiences, or Arts in Health, if there are changes in scope or in your budget, you must request prior written approval from Mass Cultural Council before making the change.

For general organizational support programs (Operating Grants for Organizations or Cultural Investment Portfolio), we understand this can feel less intuitive since your “project” is your organization’s overall operations. In these cases, the organization itself is considered the project. That means significant organizational changes — for example, a major budget shift, or program restructuring, or changes that materially affects your operations — should be reported to Mass Cultural Council. Routine variations in day-to-day programming are not considered “project changes” and generally do not require prior approval.

What happens if I make a mistake?
Mistakes happen, what matters is how you respond. Most issues can be resolved without penalties if reported promptly.

Let Mass Cultural Council know.
Work together to fix the issue.
Keep documentation of the correction.

Financial Management & Recording Keeping

What documentation should be maintained for compliance?

Copies of all subaward agreements and amendments.
Financial records (invoices, payroll, receipts, ledgers).
Performance reports and outcome data.
Evidence of compliance with civil rights and nondiscrimination laws.
Procurement documentation (if applicable).

How long do we have to keep grant records?
At least three years from the final financial report’s due date — longer if requested.

What’s “period of performance” and why does it matter?
It’s the official start and end dates for your grant project. Only costs incurred within this period are eligible, and activities must match what was approved in your application or later amended.

Can we earn income during the grant period?
Yes — “program income” (ticket sales, fees, rentals) can be used for allowable project costs, if it’s earned during the period of performance and tracked properly.

Procurement, Publicity & Accessibility

Do procurement rules apply to us?
Yes, if you use federal funds to buy goods or services. That means:

Open and fair competition.
Documenting vendor selection.
Using the right method based on purchase size (micro-purchase, simplified acquisition, or formal).
Avoiding conflicts of interest.

How do we handle publicity for NEA-funded activities?
You must credit the NEA and Mass Cultural Council in all publicity, materials, and announcements, using the approved language and logos.

What if a participant needs disability accommodation?
Under Section 504 of the Rehabilitation Act and the Americans with Disabilities Act (ADA), you are required to provide reasonable accommodations and ensure that your programs, activities, and facilities are accessible to people with disabilities. Accommodations may include, but are not limited to:

Providing qualified interpreters or real-time captioning for individuals who are Deaf or hard of hearing.
Making printed and digital materials accessible, such as offering large-print, braille, or screen reader–compatible formats.
Ensuring that facilities are physically accessible, including entrances, restrooms, and seating.
Allowing for service animals when needed.
Making reasonable modifications to policies or practices when necessary to give equal access.

You are not expected to take actions that would fundamentally alter your program or impose an undue financial or administrative burden. However, you are expected to make good faith efforts to provide meaningful access and to work with participants to identify reasonable solutions.