HIPAA: Does use of a qualifier mean validation should be done?

I am trying to classify an error level for a rejected data element,
DMG02, where DMG01 is "D8" and the data value in DMG02 is "19999999";
obviously there is no month 99 and no day 99.

Claredi calls it a Level 1 error - against X12 Standard Requirements.
I disagree with this assessment.

In my mind, the only validation that is required relative to X12
Syntax Requirements is that the field is type AN and sized from 1 to
35 bytes.

From a pure X12 standpoint, does the use of a qualifier imply a
forced validation of the format of the data element that it
qualifies?

I guess the possible answers would be:
1. no validation is required; only X12 AN and 1-35 applies
2. validation is required that 8 numeric values exist
3. validation is required that 8 numeric values exist and the
subportions are expressing proper ranges 1-12 for MM and 1-31 for DD
4. If 3 - then leap year rules also apply?

Thanks
Anthony Beecher