I just stay consistent since that makes it easier to track. Since I use the fudge factors recommended, I just stay with that same system even if I do a flat run. That way I don’t have to decide whether something had enough elevation gain to justify using hrTSS or not.
As noted a bunch here, the TSS thing is an “imperfect but the best we have” proxy, so I don’t sweat a few TSS here and there. I look at the longer term (weeks, months) trends to see if they’re following what I’m supposed to be doing.
I think the only way I’d change to using rTSS is if I decided I was going to spend a 3-6 month block training for flat running goals. Maybe others have different opinions.