The added wording in '08 " electrode encased by at least 50 mm (2 in.) of concrete, located horizontally near the bottom or vertically, and within that portion of a concrete foundation or footing that is in direct contact with the earth, " caused concern only that portion of the of the footer/foundation in contact with the earth was a CEE.
We have always allowed a section of rod to be stubbed up for connection so I guess it's no different.