When a Commission proceeding arises out of the same nucleus of operative facts as an earlier proceeding, the Commission will treat the later proceeding and the earlier proceeding as a single Covered Action. Rule 165.2(a)(1). The Whistleblower Office may post an amended Notice of Covered Action (“NCA”), with a new application deadline, for any whistleblowers who did not apply in response to the original NCA, but who believe, based on the resolution of the later proceeding, that they assisted in the Covered Action. All applicants for either the original NCA or the amended NCA will be considered for an award on the entire Covered Action.