Yes and no.

William Ford Nichols, the second bishop of CA of PECUSA, in his “Some world-circuit saunterings” (1913):

“Another special interest in going the well known round of St. Petersburgh, which included the points associated with Peter the Great, the Monastery of St. Alexander Nevsky, with its famed Choir of Monks, the meeting place of the Douma, Cathedral of our Lady of Kazan, etc., was the hope of finding Bishop Nicholas, with whom the Saunterer had cordial relations when Bishop Nicholas lived in San Francisco as Bishop of Alaska and the Aleutian Islands. He is now a member of the Holy Governing Synod of Russia and among the most eminent ecclesiastics of the empire. He did not happen to be in town at the time of our visit, and there was no opportunity to revive the memories of the days in the early nineties when there were such pleasant interchanges as the invitation in 1894 to the Saunterer to attend the services commemorative of the one hundredth anniversary of the establishment of the Russian Orthodox Mission in North America, and the attendance of Bishop Nicholas and two of his priests at our Christmas service in St. Peter’s Church, San Francisco. The great fire of 1906 and removals have left now no vestige of the buildings associated with either event but this happy memory….The Saunterer has a card of Bishop Nicholas on which he is styled Bishop of the Russian Orthodox Church in the United States of America, he having previously borne the title of Bishop of Alaska and the Aleutian Islands.”
http://books.google.com/books?id=raI8tO9xfq4C&pg=PA146&dq=Saunterer+Bishop+Nicholas&hl=en&ei=BHDQTJvFD8O4ngft5oSOBg&sa=X&oi=book_result&ct=result&resnum=1&ved=0CCUQ6AEwAA#v=onepage&q=Saunterer%20Bishop%20Nicholas&f=false

It seems the title had officially been used unofficially for some time.

I’m trying to get the original Russian of the Ukaze to Bp. Josafat, it seems was appointed bishop of America. The biography of St. Innocent states that his original ukaze from the Holy Governing Synod was for America, but the Czar changed it to the Kurile Islands. It seems the PECUSA-Orthodox detente at the time seems to have precluded making it official until St. Tikhon.