I can see this reading both ways. I'm extremely skeptical of Autopilot/FSD claims, but it all depends on interpretation. All of the currently available documentation states that Autopilot/FSD can give you a "take over immediately" warning and disengage when it has no idea what to do. It would make sense, then, that the system would detect that a crash is imminent, and have absolutely no idea what to do to avoid it, and error out, handing control back to the driver.

I think the full story on a crash is kind of required to make this conclusion. The whole point of the NHTSA investigation is to see if Tesla is massaging the data like this. It wouldn't really surprise me either way, but I'm really skeptical that Tesla would report that Autopilot wasn't engaged on a technicality when investigators will clearly turn it into a PR disaster if it's true.