True. Or, if e.g. the popular ADS1115 is used, the range is selectable from 256mV all the way up to 4096mV.
Moreover, maximizing the ADC's range isn't necessarily the most important target. Determine how much resolution the application needs and then optimize for it. Maybe you need only 9 bits out of an A328P's 10 bit range, or 15 bits out of the ADC1115's 16 bit range. That immediately allows you to 'only' swing voltages up to half the ADC's full range voltage while still maintaining required resolution...