That's a good point, but with the shallow hardening steels commonly used, they can do the same thing to a lesser extent. The surface/cheeks cool faster than the thick interior, so the center may still be soft a little further down.
Industrial definitions for "shallow hardening" are way less shallow than one might think. I'm seeing specs for a maximum through-hardening of 60-63mm for 1045, which is roughly 2.5" deep. With simple oil quenching I'm seeing a through hardening max depth of 1/4" as a figure, which should get you pretty far back into the bit without issue.