I've used Intel Power Gadget to determine the temperature of the original 256 SSD with default heat sink and the Samsung 870 NVMe without a heat sink and the Samsung constantly is one to three degrees lower than the apple during the same tasks. Although the final decision of course is on the user.
Here's a snippet from Samsung:
"4) Do I need a heat sink for optimal performance of the Samsung NVMe M.2 SSD?
Samsung NVMe SSDs rarely require a heat sink, yet maintain optimal performance thanks to Samsung’s advanced design and manufacturing capabilities coupled with an integrated, heat dissipating thermal label. In rare instances of extreme workloads (transfer of several hundreds of GB), performance may be throttled through Samsung’s dynamic thermal throttling algorithm to protect the SSDs integrity.
Please be aware, however, that an external heat source such as a high- powered graphics card, or CPU placed in close proximity to a Samsung NVMe SSD, can adversely affect air flow around a Samsung NVMe SSD which may lead to performance degradation. Therefore, please ensure there is appropriate air flow around your Samsung NVMe SSD. "