Yes, though uncommon,
Many techs push the calipers back, sending the fluid back up the lines, through the abs and back to the master.
Not loosening the rake fluid cap while doing this doesn't help either
This can roll a seal in the master, send dirty fluid back up through the system, etc
The best practice is to open the bleeder while pushing the piston in, then top up the system.
Most people don't do this(inc me) unless the service manual says to