The terminology is a little odd - for activities in 2009, we are earning elite miles for 2010 status; any elite miles earned based upon charges in 2009 count toward the status that'll be in effect for all of 2010. Of course, with AmEx being AmEx*, I would be certain that I hit the milestone before the last statement mailed out in 2009.
* I carry the Platinum now but will consider the Reserve in 2011.