Having taken a closer look at both plates today, Scott, that is correct. But with the '90-'99 Legacy/Outback, there is no removable sub-frame like Steve's Imp. There are holes on the bottom of the rad support on my generation.
Indeed, you would need to drill two new holes for the front of the plate. Still simple and well worth it.
Now comes another issue, If you are running an UEL header, you will need to space down the plate so far that it is pointless. Suppose I could notch a section of the plate off to compensate the header.