I’ve never heard anyone say specifically that 1095 doesn’t need any soak time,… but have heard the quenching process described as bringing it up to critical and quenching it. It is true that the blade is heated to above non magnetic and quenched. So, I figure it’s just a communication and linguistic shortcut rather than an actual shortcut in heat treating,... and maybe some false assumptions about other smiths heat treating based on very few words.
A quick file skate test really won’t tell you everything you need to know about a blade, but neither will any other single test. However, I think we should be aware that a quick file skate test is not the same thing as serious hardness testing using files. To describe hardness testing using files as simply, “it skated a file” may also often be just a shortcut in verbal communication.