Well, pedantically speaking, providing a free app is also a technical issue and not only a business one. Many of the paid apps have no in-app payment set up at all. For the OUYA, you'd need to implement that. Which is easy, but there's still some engineering and design time to invest to adapt (some) apps to the OUYA.
Tho, as an IAP advocate myself, I'd argue that every game dev in their right mind should have that already by now. And I applaud OUYA for "forcing" developers to do the smart thing. But unfortunately, some will still need to adapt.
But you're right, I'm just pointing a detail.