For the ATO to issue a BIFM, it has to be in accordance with their Operations Manual/CPL manual. The qualifications for the instructor will be in the Ops Manual. So if an ATO issues a BIFM, then it can be used for the credit.
To stir things up - what about the IMC rating? All 15 hours can be credited on CBIR! (But only 10 hours of the course have to be conducted as IF)