If you're worried about BIOS flashes you can get one with a true dual BIOS. That way if something goes wrong with the flash it can recover.
The only way to be sure that you get one with a new BIOS out of the box is to get one of the brand new boards that never had an old BIOS. Otherwise you always run the risk of getting old stock. Also order from a high volume place (like Newegg) and that will improve your chances of getting the newest stock.
I've already flashed the BIOS on my board twice for my Phenom II.