Interim rules have been issued implementing procurement-related provisions of the American Recovery and Reinvestment Act of 2009 (Recovery Act), which was signed into law on February 17, 2009. 74 Fed. Reg. 14622-52 (Mar. 31, 2009). One of the interim rules prohibits the use of funds provided by the Recovery Act for any project for the construction, alteration, maintenance, or repair of a public building or public work unless all of the iron, steel, and other manufactured goods used as construction material in the project are produced or manufactured in the United States, subject to certain exceptions. Another interim rule requires contractors that receive awards funded in whole or in part by the Recovery Act to report quarterly on the use of such funds. These reporting requirements apply to nearly all Recovery Act-funded contracts, including commercial item contracts, commercially available offthe- shelf (COTS) item contracts, and contracting actions below the simplified acquisition threshold. Other interim rules provide for whistleblower protections and access by Government auditors to contractor records and personnel under contracts involving Recovery Act funds. The interim rules went into effect on March 31, 2009. See also 74 Fed. Reg. 18449 (Apr. 23, 2009) (establishing Government-wide guidance and standard award terms for agencies to include in grants, cooperative agreements, and loans funded under the Recovery Act). In addition, on April 3, 2009 the Office of Management and Budget (OMB) issued updated Government-wide guidance for implementing the Recovery Act, including guidance regarding the award and administration of contracts and grants. This guidance can be found at Other OMB guidance relating to the Recovery Act, including guidance regarding requirements with respect to grants and cooperative agreements, also may be found at (For a discussion of how these interim rules may provide the basis for significant future False Claims Act liability, see the Practitioner’s Comment at the end of the article.)