Only if the actual facts satisfy the applicable employment requirement and other eligibility conditions at filing. The anniversary may be misleading where travel, U.S. employment, leave or changes in the employing organisation affect the calculation.
Use a reviewed eligibility date
Have the chronology assessed before announcing a U.S. start date. Distinguish the date the requirement is met from preparation time, adjudication and any visa or admission steps.
If additional qualifying time is needed, preserve ongoing records rather than trying to cure the issue with a stronger technical letter. An anniversary is a prompt to check rather than a conclusion, since the period that matters is the one the applicable rules recognize and that may not coincide with the date the employee joined. Use a reviewed eligibility date instead: the date counsel confirms, on the documents, that a qualifying year within the relevant window can be established.
Build the schedule from there. Allow time for the audit itself and for resolving whatever it uncovers, which in practice is usually a records problem rather than a substantive one. Where the intended filing date may move, recheck the window rather than assuming the earlier conclusion survives, since the three-year period runs backward from a moving point and a delay can remove a period the case was relying on.