No idea, but I think it's just a general error code. In Murdered: SS, it gives me the error when trying to load a new area. When it fails to load, the PS4 closes the application and gives the error code. I imagine Madden is doing something similar. No need to patch a game unless it's got a major problem.
Outside of Murdered, I haven't had any game give me the error since the PS4's launch, so most games are fine.