Yes, I would say that phrase counts as 4. I always tell providers to avoid saying it is "difficult to obtain ROS." What they should do is:
A) If the patient will answer, document what you can
B) If the patient cannot give you ROS, document why you can't obtain it
C) If the patient is able to give you just a few answers, document what you could get, then document why you were unable to get anything else
Example: "Patient is very lathargic today. His breathing is a little better, he is off the ventilator. Foley catheter is in place. He did not have any chest pain or abdominal pain. Unable to obtain any further ROS as the patient was quite somnolent."
Something like that - it shows that you tried to get some info, but really couldn't get much, and explains why.