It is theoretically possible. Each token only needs 37B parameters and if the same experts are chosen often, it would behave closer to a 37B model than a 671B model, since reusing experts can skip loads from system RAM.
You might still be right since I have not confirmed that the selected experts change infrequently doing prompt processing / token generation, and someone could have botched the headline. However, treating Deepseek like llama 3 when reasoning about VRAM requirements is not necessarily correct.