It comes down to the fact that HF and KS both are variational methods. This short article by Julien Toulouse gives a great description of ways to compute static/dynamic response properties. I'll just summarize the relevant portion.
We can compute derivatives of the energy with respect to any variable $x$ as:
$$\frac{dE}{dx}=\frac{\partial E}{\partial x}+\sum_i \frac{\partial E}{\partial p_i}|_{\mathbf{p}=\mathbf{p}^0} \frac{\partial p_i^0}{\partial x}$$
Here we are writing the derivative in two terms. The first is due to the explicit dependence of the energy on the variable $x$. The latter term is due to implicit dependence, with the energy depending on particular wavefunction parameters $\mathbf{p}$, which in turn may depend on $x$. For SCF methods, these parameters are just the MO coefficients $C$.
For a general method, this would require some type of response calculation to solve, as we typically don't have an explicit form for $\frac{\partial p_i^0}{\partial x}$. However, since the energy for HF/KS is variational $\frac{\partial E}{\partial p_i}|_{\mathbf{p}=\mathbf{p}^0}=0$, which zeros out this term.
So to compute the forces with HF/KS, we only need to consider the explicit dependence of the energy on the nuclear positions. However, once we want to compute the Hessian, we can no longer ignore this implicit term. If we write the Hessian as a derivative of the force in the same form as above, the force is not variationally optimal and so this terms doesn't cancel. Thus we need to determine the dependence of the MO coefficients on the nuclear positions, which is typically done using CPHF/CPKS.
You can get a rough order of magnitude estimate of a 2nd order property from just the explicit term. For example, when computing the polarizability (2nd derivative of the energy with respect to an applied electric field) Gaussian will print out an approximate polarizability, which it calculates by just contracting the dipole with itself rather than the perturbed electric density. While this can sometimes be close to the final result, I'm not aware of any formal bound on the size of the implicit contribution, so in general it would be a major approximation to neglect the perturbation of the density.