I think it's not only probable, but explains most of the very solid and repeatable contacts many VHF-UHF-SHF'ers make over 200-300-400 mile paths using amateur power levels and good antennas. I can work over to Phoenix (400 mi) or up to the Bay Area (350 miles) "any old time" on 70cm, just running 200W and four Yagis (with the other guy doing about the same)...repeatedly, every day. That's w-a-a-a-a-y over the horizon, and it's not a duct because when we're lucky enough to catch a duct, signals go from S1 to S9+ very quickly and stay that way until the duct fizzles out. Almost every experienced VHF-UHF guy I know can do the same kind of thing. Now, many can also work meteor scatter every single day, and those path losses are worse. It doesn't take huge power or huge antennas, it takes knowing how to do it, and with lower power can be achieved using a weak signal digital mode that keeps trying until the contacts are completed (like FSK441). Prior to that, I worked m.s. literally every evening (or very early morning) on 6m by running 1500W to four 5-L beams, or on 2m running 1500W to four 21-L beams using SSB (and talking fast!) and so did everybody else who wanted to do this and was similarly equipped -- which is an awful lot of stations! The m.s. contacts were usually in the 500-900 mile range, sometimes a bit more.