From what I've read, she was still listed with the CIA as NOC (non-official cover, meaning that her cover -- such as it was -- was as a businesswoman), although since she may have been outed by Aldrich Ames in 1994(?), she hasn't actually worked undercover since then. Sloppy bookkeeping? And the relevant statute seems to refer only to someone who has actually worked undercover outside the United States in the preceeding five years. Which she hadn't.
Sheesh, Gergan on MSNBC is saying it was a great, most articulate pressers he's ever seen.