I doubt any super looks at the design style. They probably look at the amount of hand work, number of bunkers to rake, and then the amount of steep slope to maintain, since those tend to cut into his most efficient operations - production mowing. (Let's not forget that there is a reason turfgrass has become the prevalent ground cover in the US - it is generally very easy to keep alive. As Tom Doak notes, keeping it to a certain prescribed level isn't as easy!)
Thus, if a minimalist design like Wildhorse, which has gentle slopes and doesn't add to them would be more budget friendly as opposed to Tobacco Road, or any more typically created mounds and slopes. However, a minimalist design on flat ground, with poorly drained soils could be a maintenance nightmare versus a course with well shaped fairways and a minimalist design on steep ground, where the designer left steep slopes, rather than modify them would also be tough.
Also in the mix are green and tee sites in shade or still areas, marginal turf types, which might be more associated with minimalism, and amount of landscape areas to maintain, which probably wouldn't.
Net, net, I doubt the design style label means much. Its whats out there on the ground.