Alternatively, it's Tetris with bits of a minimal OS mixed in, just enough to support it, which is not unlike what a lot of OSs in embedded systems are like.
A lot of software was written in this format several decades ago, including many games:
https://en.wikipedia.org/wiki/Self-booting_disk
https://en.wikipedia.org/wiki/List_of_PC_booter_games
I think the boundaries are quite fuzzy; while something like the mask-ROM firmware in a 4-function calculator or microwave would probably not be called an OS by the majority of people, how about a router running Linux, or the RTOS used in a car's ECU? Moving up from there, DOS is clearly in the realm of an actual OS, then we have the locked-down mobile devices, and at the far end are the general-purpose PCs running Windows, Linux, macOS, and such.
Even at the "small end", a microcontroller running a firmware containing a single infinite loop that does stuff with the peripherals seems unlikely to classify as an OS; but what if you start adding dynamic memory allocation, coroutines/cooperative multithreads, filesystem code, etc.?