Based on the bill’s structure and placement within DHS, the proposed Ombuds differs in key respects from IOA standards. The bill assigns the Ombuds responsibility for providing confidential and objective assistance in resolving internal concerns and making recommendations to leadership. However, the statute does not expressly reference independence, informality, or neutrality as defining characteristics of the role. Moreover, it is not clear whether this would replace or amend the prior DHS Office of Intelligence and Analysis Ombuds, which was more organizational in structure. The full statutory language will determine the extent to which the role aligns with IOA standards of practice. (H.R. 7435, 119th Cong. (2025–2026), “DHS Intelligence Transparency and Oversight Program Office and Ombuds Act.”)

The real question is: will the unitary executive follow an Article I directive related to an Article II agency?
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