The headline is correctly using the term according to the NHTSA definition as a requirement for the manufacturer to fix an unreasonable safety issue. Whether it is OTA does not change the fact that it is a recall any more than if a manufacturer sent someone onsite to fix a mechanical issue instead of having the vehicle owner bring it in.
The fact that this thread is full of people who envisioned a physical recall is evidence enough the word is misleading. If reuters was an industry journal, sure.