From my understanding it would definitely be better to have your element as low as practicably possible ( this has the benefit of utilising more volume too). But your temperature sensor is still only going to read the temperature of its surroundings. If you have it below the element it will read cooler, if it is directly above the element it will be affected by the temperature of the element itself, if it is too high in the vessel it will read hotter than the bottom and be exposed sooner blah blah blah.
If you don't recirc, like stated above, it's just a matter of stirring the HLT to stabilise temp before you take a measurement. But... if you have a spare pump and fittings... you'd be doing a disservice to the Beer Gods not to use them.
At the end of the day, it's not super critical but there's no harm in trying to eliminate variables if you're that way inclined.
My 2c anyway.