Unusual on a newer car using OE quality sensors. By "upstream" I assume they mean the pre-cat lambda - this sensor is important (once the engine warms up) in controlling the precise combustion mixture in conjunction with other sensors like the MAF sensor. Sometimes the combustion mixture further upstream can be so far wrong (because of something like a huge hole in a vacuum pipe) this lambda sensor will struggle to cope with corrective action out of its range and therefore, throw an error code. This can result in DIY mechanics wrongly assuming the sensor is faulty when something else is causing the problem.
If you have had this analysed professionally, I can only assume this sensor has been properly identified as the problem and that you have either suffered extremely bad luck or that it was not actually changed last September