Is it likely that an ABS module would need to be replaced after 3 years?

Seems like a "normal" problem on that vehicle. You did well with the first module, 5 years. There is a electronic procedure to purge the brake fluid from the system that may help. It's work a try.

I am also experiencing the same problem with my 2008 Milan. If you find a solution, I would be interested to know!

My 08 Milan has the same issue. This has been going on for about a year now. This past weekend was probably the 6th (and final) time. I made an appointment for an $1,100.00 repair to replace the ABS pump and module and I will be driving straight to the dealership for a new car because its all over the internet how this ABS system in Ford is a POS. It should be recalled. I hope that you are in a position that you can get rid of your car. I hope that you stay safe. I encourage you to report it to the NHTSA website and file a complaint https://www-odi.nhtsa.dot.gov/VehicleComplaint/ if enough of us report the issue, they will have to issue an investigation/recall.