On my Model S, I did have had the firmware rolled back to a previous version one time. There were no errors to my knowledge and I'm not sure why they did it, but it is possible. I don't believe there's a "factory reset" in the same way a motherboard might have a redundant firmware/bios stored somewhere. "Factory resets" like you'd do with a paperclip on a router typically don't change the firmware, but reset all the custom settings and user configurations that may be causing an error. That said, I wouldn't be surprised if Tesla had a way to update firmware with special tools--possibly hardwired to the car--in the event of a serious firmware update issue.