Furthermore, I think that by r’iyah he does not mean incidental (he specifically says that there is makkos only when there is kavanah) but rather where there is intent for r’iyah but not for hanaah. In contrast, histaklus of mokomos megulim is only assur if there is intent lhonos.
I’ll accept your phrasing, but the point I’m making is that it is obviously a chiyuv for a woman to cover that which is assur for a man to see (even without ????? ??????).