The effects will be immediate and devastating.

8. The effects will be immediate and devastating. Medical schools, scientific research institutes, and other grant recipients across the country have structured their programs and development of physical infrastructure assuming that the substantially higher indirect cost recovery rates would remain in place, and that any changes to those rates would be based on actual changes in cost. The rates were negotiated with the relevant federal agency through a wellunderstood legal process and in reliance on NIH’s longstanding approach. Even at larger, wellresourced institutions, this unlawful action will impose enormous harms, including on these institutions’ ability to contribute to medical and scientific breakthroughs. Smaller institutions will fare even worse—faced with more unrecoverable costs on every dollar of grants funds received, many will not be able to sustain any research at all and could close entirely. In a public statement, the Council on Governmental Relations has already called this brazen act “a surefire way to cripple lifesaving research and innovation.”2 As the Guidance acknowledges, NIH’s work—and the work of research institutions that receive NIH funding—serves to “enhance health, lengthen life, and reduce illness and disability.” NIH’s extraordinary attempt to disrupt all existing and future grants not only poses an immediate threat to the national research infrastructure but will also have a long-lasting impact on the country’s research capabilities, and in turn, its ability to deliver positive outcomes for all Americans and individuals around the world.