No, that is not right. Your status is reset to 0 the first time you hit Gold, but after that it is not reset until the end of the 12 months period.

So, If you hit Silver in Jan 2006 (either through flying or through comp), your status is reset to 0 and you have until Jan 2007 to make it to gold. If you reach Gold by April 2006, your status counter is reset to 0 at that point, and you have until April 2007 to reach gold to keep it for another year. If you manage to accumulate 38K between April and July, there will be no review and no resetting of points. It will only happen in April 2007, at which point they will reset your counter to 0 and you will be Gold until April 2008.
Any status miles you get in excess of 38K before April 2007 will be 'wasted', i.e. your counter will be reset to 0 whether you have 38K or 380K.