If I had to do it, that's probably how. Maybe not to such an extent as you describe, but maybe make it so that "precision hits" from a distance or on small targets (such as a weak spot) would require either 1) a big risk of getting to close to the enemy and risk maximum damage. Or 2) a significant investent in an aiming modifier (skill, stat, cyber w/e) - and yes, installing cyber has disadvantages. It takes one slot out of a limited number of them. Kinda like assigning points.When you handle accuracy through skills, combat gameplay will get gradually faster and more fluid in a much less subtle way than using damage as the core, because when the guns are somewhat lethal from the get go, the player will notice when hits happen and when he can score those hits with much lesser focus time.
I mean, as a merc, some level of weapon proficiency is to be expected, so it shouldn't be "normal" to have a targeting reticle the size of China with a pistol.
Then again I have no particular issue with a damage progression system, passive or otherwise. I've played and enjoyed both. I also played and disliked both on occasion.
Maybe what we'll get is a blend of the two, it kinda seems that way.