Long story short, the whistleblower did everything right.
Excerpts to follow.
dni.gov/files/ICIG/Doc…
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** (emphasis mine)
transmitting the information to the Acting Director of National Intelligence on August 26, 2019."
ICIG understood that "certain language in those forms and, more specifically, the informational materials accompanying them, could be read–incorrectly–as suggesting that whistleblowers must possess first-hand information" to file an urgent concern complaint