From xboxlive.ign.com:

The announcement that video streaming service Netflix would be headed to PlayStation 3 next month left many wondering if Microsoft would respond by dropping the Xbox Live Gold membership requirement to use the service on the Xbox 360.

That answer, as of today, is no.

A company spokesperson reiterated to IGN the value of Xbox Live Gold status, saying it's online experience is still "a generation ahead of the competition" despite a yearly subscription cost.
Full Story: xboxlive.ign.com