Interestingly, I found what caused the false-negative. If I used Vim to create the file, it was picked up. If I "echo ...EICAR > text.txt" it doesn't get picked up, at least not immediately!
The on-access scanner intercepts requests to open files, and scans them. Echo just writes to the file and closes it. It doesn't try to open it again once the EICAR string is in there. I'm speculating here, but Vim probably writes the file/buffer, flushes, and then tries to obtain a file handle to it. At that point an on-access scan will occur, and it will find the EICAR string.
