It certainly sounds like a bug in the product.
I'm afraid that we cannot do much here. Well, we could ask you to post a repro that demonstrates the issue, but that could take you a bit of time. And in the end we might only say "yes, we can repro this", but unless there is something that stands out as special, I don't think that we will be able to help you to get around the problem.
So I would advice you that you first check "SELECT @@version" and verify that you are on CU11 of SQL 2019. If you are not, apply CU11, which is the most recent CU for SQL 2019, to see if that it helps.
If it does not, open a support case, if this is a blocking issue for you. (And I guess it is.)
Well, an alternative is of course to replace the MERGE with individual INSERT and UPDATE statements, and there are blog posts out there that gives MERGE bad press. But I find MERGE quite nifty myself, so I am not keen on that workaround.