Independent Technical Risk Assessments (ITRAs) are required by law for Major Defense Acquisition Programs (MDAP) and are conducted by the Under Secretary of Defense for Research and Engineering (USD(R&E)).  As the name implies, the purpose of ITRAs is to give the Milestone Decision Authority an independent risk assessment at major decisions points like the  Development Request For Proposals Release Decision (DRFPRD).  The release of the RFP at the release decision point establishes the contractual basis for the entire Engineering, Manufacturing, and Development phase.  So, providing the ITRA at the Milestone B Review is too late.  Public Law and USD(R&E) Policy Memorandum for Independent Technical Risk Assessments (Jun 2018) indicate that the correct point for the ITRA is at the DRFPRD point and not Milestone B.  Previous memos or directives suggesting that the ITRA by conducted for MS B were in error.