Deep learning (DL) has shown promise for faster, high quality accelerated MRI reconstruction. However, standard supervised DL methods depend on extensive amounts of fully-sampled ground-truth data and are sensitive to out-of-distribution (OOD) shifts, in particular for low signal-to-noise ratio (SNR) acquisitions. To alleviate this challenge, we propose a semi-supervised, consistency-based framework (termed Noise2Recon) for joint MR reconstruction and denoising. Our method enables the usage of a limited number of fully-sampled and a large number of undersampled-only scans. We compare our method to augmentation-based supervised techniques and fine-tuned denoisers. Results demonstrate that even with minimal ground-truth data, Noise2Recon (1) achieves high performance on in-distribution (low-noise) scans and (2) improves generalizability to OOD, noisy scans.