(1)
Except as provided in subsection (b), if the Special Counsel determines that disciplinary action should be taken against any employee for having—
(A)
committed a prohibited personnel practice,
(B)
violated the provisions of any law, rule, or regulation, or engaged in any other conduct within the jurisdiction of the Special Counsel as described in section
1216, or
(C)
knowingly and willfully refused or failed to comply with an order of the Merit Systems Protection Board,
the Special Counsel shall prepare a written complaint against the employee containing the Special Counsel’s determination, together with a statement of supporting facts, and present the complaint and statement to the employee and the Board, in accordance with this subsection.