$ref{$key}{NAME} and ${$ref}{$key}{NAME} are two completely different things. But you can say that the latter is another form of arrow notation (the first arrow, because it's a dereference operator), so they are both a hash reference.

my $env = \%ENV;
print $env->{SHELL};
print ${$env}{SHELL};
print $env{SHELL}; # barks under strict, undefined otherwise

# output:
/bin/bash
/bin/bash
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