Wow, I think you might be stricter than me! lol, its not often that I am the less conservative view.
Unfortunately there is nothing out there that requires notes to be structure in a particular order. PFSH are what they are, they can't be discovered on exam or diagnosed, so where ever that info is in the note, how could you not give them credit for it?
If an auditor dropped my level because they said PFSH was missing and I found it in the note, I would challenge them.
Obviously in a perfect world everything would be in its place, until that happens though we just have to deal with what we have. I am an auditor, I work with a lot of other auditors (mostly external to my organization) we may disagree on HPI and ROS but PFSH has never been an issue, now that I say that it will probably come up.
Laura, CPC, CEMC