 The use of the phrase "like the Cabinet-level departments" could mean that, in addition to the Cabinet departments, other entities within the executive branch that are sufficiently analogous to the Cabinet departments may qualify as "Departments" for purposes of the Appointments Clause.On the other hand, the Freytag Court itself seemed unclear what it meant by the phrase "like the Cabinet-level departments," and certainly stepped back from any bright-line test.The Freytag Court sought to harmonize its analysis with the interpretation given the different term "executive Departments" in the (which has been interpreted to refer only to Cabinet departments) and with earlier cases that suggested that only the Cabinet Secretaries qualified as "Heads of Departments."