Not really, because thematically, the gameplay is completely disjointed from the rest of the game. And as it is a GAME, I'd say that's a pretty huge dent in its thematic armour.
The gameplay has little to do with it. This seems to be the game that everybody wants to say is a case for the form's legitimacy as art. And as long as games have to be fun to be appreciated, they can't really be art. There are plenty of great, deeply artistic films and texts that aren't remotely fun (nobody demands that Wild Strawberries have more explosions and car chases). And that's what I mean when I say that it's a thematic work. That it's not fun doesn't matter. It's up there with Fallout and PS:T even when it isn't (hell, it's much funner than PS:T), because it's merit isn't in its gameplay but in the deconstruction of the form and the themes it presents.
That's a pretty strict definition of fun you have there. Just because artistic films are entertaining in a way that doesn't appeal to most people, it doesn't mean that they cease to be fun. Personally I found, say, Persona (haven't seen Wild Strawberries yet) a lot more fun than, for example, The Fast and the Furious, regardless of the larger amount of action scenes in the latter. With this in mind, I don't think it's reasonable at all to oppose artistic merit to fun, especially when they are inherently subjective concepts.
What I'm saying is that for a game (any game) to be a successful deconstruction of the form and the themes it presents, it also has to do that deconstruction through its gameplay, especially when the target is FPS gameplay.