The answer is “no” according to the recently-released guidance memo by the Office of Management and Budget (OMB). Well, sort of.
Section 4.3 of the updated Implementing Guidance report states:
“To maximize transparency of Recovery Act spending required by Congress and the Administration, agencies must not co-mingle Recovery Act funds with other funds in apportionment requests they prepare for OMB…”
However, it further states agencies CAN use stimulus funds for existing projects IF they establish separate internal accounting codes to explicitly track these funds.
So, agencies may use Recovery Act funds to complete projects already started if the fund sources are clearly identified. This highlights just another dimension of the significant impact new reporting requirements will have on recipient agencies–and ultimately many subcontractors wishing to sell to these agencies.