Undrave
Legend
This isn't nearly so much a problem, as it's easy to say that Tom was smart all along.
But once Tom's Int score gets locked in at 15 it stays there. His stats don't all change if he leaves the low-level party he just joined and meets a higher-level crew three days later (let's say they take him on as a hench) - he is what he is, and consistency is maintained.
But the Ogre's stats do change. If Tom's low-level party meet the Ogre, realize they can't kill it, and run from it; then Tom's higher-level party meet the same Ogre four days later it's the same Ogre and therefore should have exactly the same stats as when Tom met it the first time.
Put another way, a monster's stats serve a greater purpose than simply how it relates to the PCs: they represent in an abstract way how it relates to the entire setting, whether PCs are present or not.
I mean... how would party A know that Party B already encountered this specific Ogre? A lot of your problem with the approach could be fixed by... simply not having the party encounter the exact same individual ogre as different incarnation. Heck, maybe your party doesn't encounter Ogres beyond the one time they fight the Boss version. They don't KNOW the Minion version exist. Or, maybe the opposite. Your party was fighting Kobolds and Dragons for a while and now that they're fighting Giants they meet Ogres for the first time and they're minions. They don't know that ten level earlier the same type of creature would have been a solo.
Just because the stat block is there doesn't mean it has to exist in your world, nor does it mean your PC have to encounter them.
You can easily get away with saying the Solo they fought at lower level was a unique individual and the Standard Monster version is the only thing they encounter from now on and never use the Minion version. 4e Monsters are pretty easy to adjust on the fly so you can have them keep up in terms of accuracy but their HP and dmg remains the same so they're not as dangerous the more the PC level up.
Stat blocks are just tools.