AMCs set their own rules (generally) and have more flexibility. So I guess the answer is technically yes, but realistically probably not? Pull in a $25,000,000 grant and I wager many AMCs would make an exception though.
VA - no. Unless they interned at one of those "VAs that was applying for accreditation but didn't have it yet" for which they created an exception to the rule.
If you are referring to a hybrid position, its likely some combination of the above two answers. These situations are often outrageously complicated. I don't know if the rules applied to someone who isn't paid by the VA - I imagine it likely depends on the exact context, time spent, activities involved, etc. I don't know if WOC folks need an APA internship too or where exactly the line is drawn.