Yes, although I think by introducing Touch AC, it allows you to freely but accurately describe situations where missing or ineffectively hitting is important.
Just three states will do:
1) Miss (not make touch AC),
2) Ineffectively Hit (make touch AC but no AC), and
3) Effectively Hit (making AC).
This should be enough to cover issues such as contact poison, reaper damage, magically damaging touch and so on where isolating one of these three is logically important.
You separate physical wounds from everything else hit points represent (morale, turning a blow, luck, divine providence, skill etc.). Hit points then have the freedom to represent a reaper terrifyingly miss their opponent; the close call whiff - not making touch AC but taking away "morale" hit points. Alternatively you can wear them down by forcing them to block their blows (making touch AC but not their AC) and incurring a like number loss of hit points.
Best Regards
Herremann the Wise