I think you mean 10 years at the most. And I think the 10 year timeline you reference is for non-official cover. She may have traveled outside the US with some sort of other cover in the past ten years. But that wouldn't trigger the Intelligence Identities Protection Act.
You are absolutely right. I stand corrected. I certainly meant 10 years at the most as I certainly do not count anything beyond 1994 as covered by the IIPA. Thanks for clarifying my comment.