The most common cause of this code is exactly what you described. However, other things can cause it. Here is a description of the code and how it correlates with the PCM:
The Power-train Control Module (PCM) monitors the Exhaust Gas Re-circulation (EGR) valve pintle position input to ensure that the valve responds properly to commands from the PCM. When the ignition switch is turned ON, the PCM learns the EGR learned minimum position. The PCM compares the EGR learned minimum position to the EGR position sensor when the EGR valve is commanded closed. If the EGR position sensor indicates that the EGR valve is still open when the PCM is commanding the EGR valve closed, this DTC will set.
Since you already replaced the EGR and there are no carbon issues, that leads to testing. I have attached two pics below which are basically a diagnostic flow chart for determining the cause of the problem. Take a look through them and see if anything helps.
Let me know.
Images (Click to enlarge)
Sunday, December 13th, 2020 AT 1:13 PM