oomis:that is the shiita of the Rashba who says that a person is a briya chadasha and one should wash like a kohen does. The Rosh holds because one could have touched an uncovered part of his body while sleeping,and then there is the issue of Ruach Raa(which a bracha was not instituted for). A good nafka mina would be if one would wear mittens to sleep does one make a bracha,this has been discussed already.
Superme:It depends if we hold that our bathrooms have ruach raa or not. Rav Moshe discusses this.