On paper sure, but ODNI & CIA are interchangeable highside. The NRO is spun off the CIA, NSA’s network sits in a network gated by the CIA, and everything under DIA is overseen by the NSC which is “advised” by the CIA. They also control all HUMINT which is critical to the mission of nearly every agency.

Would also mention the last two DNI were CIA directors. The two before that were NSA directors during a time where the NSA was largely controlled by the CIA and its leadership largely shared positions on the CIA’s senior leadership team.