I think you might want to ask them how they would make the determination between what was a portrait and what was figurative.

Here is a quote from the FAQ section on the NPG site:

"How do you define

I entered a painting. The form asks is "what is the relationship of the artist to the sitter" - in my case I entered a portrait of my my son, so of course I could wrote "mother" . They also give ample space for you to discuss the sitter, the motivation of the painting, and any artistic comments.
One other question they ask is what is your website if any, so I would expect they are not just looking for amateurs. but get the feeling they are looking for portraits done by artists as personal projects, not commissions. Just my impression. It never states anywhere that commissioned work is unacceptable or less desired.

Can't we just prod them with a mahlsick?

Sorry. I couldn't resist.

I wonder how they'll verify this "direct contact" thing. If an artist photographs George Bush from across a crowded room at some fundraiser, would they allow that, I wonder? (Aside from the model's release/privacy issues that George Bush himself would have, of course.) If the artist says that Bush came to their apartment for dinner and they painted him from life then, what verification would they insist on?

Only one entry allowed. As far as competitions go, it's inexpensive for the possible exposure. I'll wait until the last minute to see if I produce any masterpieces before September. ;)

For those of you who are entering, Im curious - was it an easy decision which painting to enter? Or did you struggle with which one is your best?

From what I can gather, you just have to give it your best shot. If you notice on the web site they feature the works of Alice Neel and Alex Katz, two quite non traditional portraitists. Trevor Fairbrother has written books on Sargent, the woman from the National Gallery is an expert on 18th century painting, the others seem to prefer more avante garde work and have written books about Alice Neel, and Han Namuth, who photographed Jackson Pollack. So it is a crap shoot.

I just got a reply from The Smithsonian,

They said "yes you can use paid models, many artists have, just as long as you have had direct contact with them".

Too late to enter, but I did enjoy voting for the serious portraits!