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Federal Agency Risk Review Processes and Mitigation Plans

Section 10633 of the CHIPS and Science Act of 2022 provides authority to each federal research funding agency to request supporting documentation including copies of grants and contracts and other agreements for all covered individuals (Key Personnel) in a research and development award application.  The purpose of this new requirement is for awarding federal agencies to determine if existing activities will interfere or overlap with proposed agency funded activities.  Federal agencies may require a substitution or removal of a covered individual from an award, reduce the award funding amount, or suspend or terminate the award if overlap or elevated risk is identified.  Funding agencies may also request the development of a risk mitigation plan to manage higher risk activities to ensure that all funded activities are not compromised.  The following federal agencies have advertised their risk review processes:

Department of War: 2026 Department of War (DoW) Component Decision Matrix to Inform Fundamental Research Proposal Mitigation Decisions

DoW/DEVCOM: ARL Implementation of Army Futures Command (AFC) Army Research Risk Assessment Protection Program (ARRP)

US National Science Foundation (NSF)Trusted Research Using Safeguards and Transparency (TRUST)

National Institutes of Health (NIH): NIH Decision Matrix for Assessing Potential Foreign Interference for Covered Individuals or Senior/Key Personnel

Department of Energy (DOE): DOE Approach to RTES Risk


The following agencies do not have published risk matrices, but provide the following information regarding risk categories:

US Department of Agriculture (USDA): Terms and Conditions that include the following risk categories and how they are defined: General Terms and Conditions (2025) and Updates to Terms and Conditions (2026) 

  • Research Security Training -  section 10.6
  • FCOI - section 10.7
  • Disclosures - section 10.8
  • MFTRP - section 10.9

National Aeronautics and Space Agency (NASA): Terms and Conditions that include the following risk categories and how they are defined: 

NASA Grants and Cooperative Agreement Manual (2025)

  • Disclosures - section 10.6

NASA Grants and Cooperative Agreement Terms and Conditions (2026)

  • MFTRP - section 5.4