Yes. This was the policy I saw when I considered renting an EV in Phoenix. We were only going to be there for 27 hours and our hotel did not have its Level 2 charger operational yet, so we opted for a gas car instead.
I rented a Bolt from Hertz last December and their policy at the time was:
“Return your EV at the same charge level as pick-up and pay $0. Or return your EV at any level for a $25 Recharge Fee.”
They were pretty lenient about the return charge — it was close to 100% to start and 80% when I returned it, but they didn’t charge me the $25. Even if they had, the EV rental rate was cheap enough that I would’ve still come out ahead vs. renting a gas car.