Where a regulation establishes that claimant has the burden to establish statutorily required administrative exhaustion, the Board cannot require that the employee prove that they typed something into a web form in order to establish jurisdiction.
As the statute only requires that the report must be of something reasonably believed to be a crime, there is no obligation on the reporter to establish all of the elements in the crime in the initial report, or to establish that the report to the Board was identical with the earlier report to internal special counsel.
The exhaustion required by the statute is accomplished by presenting a claim to the special counsel that a legally sophisticated reader could understand and investigate.
http://media.ca7.uscourts.gov/cgi-bin/rssExec.pl?Submit=Display&Path=Y2018/D06-19/C:16-1313:J:PerCuriam:aut:T:aOp:N:2173082:S:1
Since 2011. An occasional commonplacing of the U.S. Circuit Courts of Appeal.
Neither an authoritative statement of the law nor legal advice. Quick work.