There is nothing that prevents a Soldier from receiving a negative or event oriented counseling if they have not received their initial counseling
According to ATP 6-22.1 effective counseling takes place as close as possible to the event. So it would be appropriate to counsel the Soldier as soon as possible.
Let’s say a Soldier was late for formation received a verbal counseling. Then was late again to formation and this time they received a formal counseling. This would be appropriate. There is no requirement or need to wait until the Soldier has received their initial counseling.