I believe so. One night stays are definitely not an effective use of DVC points with the $95 fee. It might be worthwhile verifying with MS, but to my knowledge, all RCI transactions thru MS will incur the $95 fee (same as a 1 night stay using points at a non-DVC WDW Resort).
Not only the $95 fee plus I'm pretty sure you'll find a housekeeping fee for almost all resorts for stays less than 7 nights. You'd be throwing your DVC points away for most options for both BVTC and RCI for 1 or 2 nights. After that, it depends on specifics.