In all truth any game can be an action game... it just depends on what you consider action.
The way you are thinking however leads me to believe that you must think Oblivion, NeverWinter Nights, Kotor, Eternal Sonata, Final Fantasy, Blue Dragon, or any other RPG must be just an action title.
What makes Mass Effect differ from Final Fantasy? It is a 3rd person game that runs its battle in real-time (Final Fantasy 12 is still not fully real-time). It has a different story, different characters, and etc.
But what else is really different besides the combat system and the conversations? In Final Fantasy you are able to "upgrade" weapons, armor, and even skills (depending on which game you play). Now you can also do that in Mass Effect. In Final Fantasy you are put into an engaging story line that develops the characters and so does Mass Effect.
Now what makes up an RPG? You role-play? Well the game does it for you because role-playing in games is like living the life of that character and trying to actually be that character and isn't that what RPGs do (putting you in the head of the character isn't the same which is what makes Shooters differ from RPGs and of course other obvious reasons).
In all Honesty many of the things that make RPGs what they are is also the same thing in many other games, but RPGs create the game around this things unlike so many other genres. Other genres create their games around their gameplay while RPGs create their game around the story.
If you say Mass Effect isn't an RPG then you are pretty much denying that RPGs are even a genre.
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