Basically, when people say "file system X doesn't need fsck," what they usually mean is that it can recover from a crash without running a program to check and repair the entire file system. (It may have to replay a few entries from the log but that's it.) Every file system still needs a "fsck" to check and repair the file system when it gets corrupted, it's just that old file systems like ext2 let the file system get corrupted at every crash.
btrfs has a rudimentary file system check. The plan is for a full-featured check and repair.