I would think this should be possible but adjustments will have to be made for sure. When you look at how the market moves, tick for tick, its pretty apparent that HFT firms can and do push the markets in a certain direction. Call it stop runs or whatever, but there can be quite violent moves that are often counter to the actual move. I don't watch currencies enough, but I imagine the same thing happens. At the same time, since currency trading isn't centralized, unlike the ES, then this more than likely changes things.
I think when you switch to a higher time frame, things get smoothed out so you don't see this as much. With day trading, getting the timing right and order entry is much more critical. If one would use a 2 or 3 point stop in the ES, then certainly, waiting a few point for price to take off from a level means that you aren't even allowing room for price to retest wherever it took off from. But if you were to swing trade the ES, with lets say a 20 point stop, and enter 10 points above some key level, then you have more breathing room.
Clearly you can have breathing room in day trading as well as your stop can be whatever you want it to be, but if the range of the ES is only 10 to 15 points, then using more than a 5 point stop will not result perhaps in great performance. Not only will price perhaps be ready to retrace after it has moved 5 points in a direction, but you also might not have enough range left in order to recoup losses and such.
But the key is that all of these things get analyzed in advance, and if you have done this for swing trading, there is no reason why you couldn't do this for day trading. In the end, the trade either works or it doesn't, and you either take the next trade or you don't. The psychology and mechanics of trading is what is most difficult to master. The actual plan really isn't too tough in comparison.