Is the bed a fixed unit type or the more typical that HO brings in what ever fits them? If typical bed, furniture, not within the realm of control of design or even electrician installing it. Any difference than if panel was in the living room, and the tenet/owner was to place a couch or a lamp and stand in front of the panel? Not in the control of the designer or the electrician.
Not sure why that would even be indicated on a set of prints, unless room layout is such that the only way to place a bed is placing the headboard in front of the panel? That then would be blocking access to the panel not just working space issue. Also, in general, it would be different if the placement of panel on design was putting it behind some peice of equipment, like a refrigerator, or a washer and dryer. Was just to one that the panel was not only in the bathroom, but also the stacked washer dryer was directly in front of it, couldn't even close the panel door. Now that was a design failure somewhere along the line, and a failure of the handiman that put the washer/dryer in.
But, no different than if design was for a utility room for the panel, as a plan reviewer you can't control what a tenan/ownert would end up storing stuff within the room. I've been on service call that it took nearly 20 minutes to clear out enough junk just to get to the panel, and that was not even clear access, still climbing over stuff. Tried to get the customer to see the safety issue of such, but don't know if it had any real impact. Have one repeat customer (he is always looking to add something or change something) that insists on putting a medium sized curio cabinet right in front of the panel. Can't get him to see the hazard of that. But from the design aspect the space was more than adequate for the panel.