The answer that I finally received from the NEA is that although they
wouldn't prohibit a departmental application, they strongly discourage it
and there is no reason to believe that their staff would accept it.

On Thu, 8 Feb 1996, Research Administration Discussion Group wrote:

> Here is my understanding of how NEA determines if a department is an
> independent component.
>
> The component must meet all three of the following criteria:
>
> be a distinct entity as an administrative and programming unit that is
> separate from the parent organization;
>
> have a separate budget and independent board of trustees;
>
> and
>
> employ a professional staff whose responsibilities are directed primarily
> to the component unit.
>
> This analysis thanks to the "Arts & Culture Funding Report" from the
> Education Funding Research Council.
>
> I can see a potential problem for many private universities trying to get
> more than one application into the new NEA: each entity needing to have a
> board of trustees independent from the university's. How it treats the
> public university/research foundation hybrid I wouldn't hazard a guess.
> university-affiliated art museums or university presses may meet these
> criteria.
>
> Remember, too, that NEA still doesn't have its budget approved for the
> current fiscal year.
>
> Bob Burke
>
> ______________________________________________________________________________
> Robert P. Burke                         (219) 631-6494
> Institute for Scholarship               fax: (219) 631-7743
>    in the Liberal Arts                  e-mail: xxxxxx@nd.edu
> University of Notre Dame
> Notre Dame, Indiana  46556
> USA
>