I am sorry to be the bearer of bad news but the requirement for comprehensive sickness cover has been in place for quite some time and not being aware is not a sufficient reason.
At this stage, she can obtain comprehensive sickness cover and once she has put the same in place and maintained it for a period, she will be able to re-apply.
I know this is not the answer you were hoping for but I do not make up the rules.
I hope this answers your question. If so, kindly rate the answer and provide feedback.
If you have any further questions, please do not hesitate to ask.
I have had a few clients in a similar situation I am afraid to say. It seems unfair.
It does change the requirement, however, as soon as she stopped becoming employed the requirement comes into effect. Therefore, in the absence of it, she will not meet the requirement of the rules.