Can two separate commands use their O&M funds to support this project as long as the total cost stays below the $750K threshold? Or is this considered co-mingling of funds or funding augmentation?
From a financial management perspective, if both appropriations are within the same funds limitation, then there isn't a fiscal issue; for example if both activities receive O&M funds within BAC 04, without any A or B limitation, then this can be done. However, stairwells are “common” infrastructure. DoD instruction 4000.19, paragraph 4.6, has this to say about re-imbursement for “common” infrastructure:
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“4.6. Reimbursement. Interservice and intragovernmental support is reimbursable to the extent that provision of the specified support for a receiver increases the support supplier's direct costs (i.e., incremental direct cost). Costs associated with common use infrastructure are non-reimbursable, except for support provided solely for the benefit of one or more tenants. Support costs that are charged to a support receiver (i.e., reimbursable cost) must be measurable and directly attributable to the receiver.”
Both the time it took for the stairwells to get to this condition and the longevity of the repairs would make one wonder how any tenant could be identified as causing the need for repair and whether that tenant would be in the building long enough to reap the "investment". .
We recommend you consult with your comptroller and legal personnel.