I would think so, but I'm not sure this is a rigorous way of looking at it. The more rigorous approach can be described in words by using the block universe approach, where one assumes that the entire history of the black merger can be described in the block universe, via a metric. The metric, then contains the entire history, past and future, of the merger.
From this metric, containing the entire history of the merger, one computes the signal in "space" as a function of "time", in some small region of space-time far away from the black hole. The problem of splitting space-time into space plus time in a small local region has a generally accepted solution, which can be described concisely by saying that the process involves using projection operators to projecting the 4 dimensional space-time into the appropriate subspaces. (This isn't very detailed, but I hope it's sufficient).
This approach doesn't have any simultaneity conventions for it to depend on, at least not until the very end of the process. At the end of the process, one usually imposes the condition that time is orthogonal to space, and that the different spatial directons are also orthogonal.
When one talks about a scenario where "the black holes just touch", my interpretation of this is that one is imposing some specific simultaneity convention, some specific coordinates, to describe the state of the black hole at some "instant in time", so one can single out a specific instant in time "where the event horizons touch".