CMS has made documentation guidelines for this relatively clear--where I (personally) find dissent is in the interpretation of presenters, auditors and educators.
According to CMS, it may be counted as either Past Med. Hx. or as a ROS (All/Imm), but only one of those. It is pretty standard for auditors/coders to just automatically slam it into PFSH, although it may be needed elsewhere (e.g., ROS). Since the allowance is permitted by CMS, I would say it needs to be counted where it is needed in the document.
If specific FIs have rules outside those of CMS, they should place those in writing. I would also pay heed to what the Medical Reviewers (not Clinical Reviewers) are stating from those FIs; these are the people reviewing your documentation, after all.
Hope this helps.