I have been testing this issue on a pair of backup firewalls that we have, so generating the error is not really a problem for us.
Upgrading to R81.10 JHF 156 did not resolve the issue; however, I did receive a hotfix for JHF 156 that appears to have resolved it. Unfortunately, this test scenario is only Check Point to Check Point, so I cannot validate third-party vendors. No news on if / when this hotfix would make it to a jumbo.
Personally, I won't upgrade past JHF 150 on my production cluster until this has been added to a jumbo, I do not want to be managing hotfixes.