Although the form requests information about whether the Complainant possesses first-hand knowledge about the matter about which he or she is lodging the complaint, there is no such requirement set forth in the statute. In fact, by law the Complainant – or any individual in the Intelligence Community who wants to report information with respect to an urgent concern to the congressional intelligence committees – need not possess first-hand information in order to file a complaint or information with respect to an urgent concern.
Thus, the IC IG decided post-submission, that firsthand knowledge was not required in the statute, therefore it shouldn't be required on the form.
As Col. Sherman T. Potter would say: "Horse Hockey!"