A bit ambiguous in the wording, but the "no game may end in a tie" rule is enforced for varsity only for the purposes of playoff seeding. NFHS rules actually specify "Regular season games that are tied at the end of 80 minutes of play may be resolved by procedures adopted by state high school associations"--which would point toward varsity only because the previous paragraph recommends 60-minute games for JV/middle school levels.
State policy has always been that a JV match may be resolved using OT/kicks from the mark as long as it does not interfere with the timely start of a varsity match to follow, but JV matches are allowed to end in ties as there is no win/loss record to apply to playoff seeding. Tim, I think you posted a 4-4 tie vs. Battery Creek this season...was that the rationale in that case?
Sometimes it depends on the officiating crew and how quickly they want to get home.