Again size has absolutely nothing to do with it.
You could have a slab the size of Arizona and if it does not support a building or structure it is still not a footing or foundation. :smile:
Even slab homes usually have a stem wall that is supported by a footing.
Here is a slab on grade construction detail, the slab is slab and the part heading down into the earth is a footing.
Here is another that sounds a lot like your installation.
The footing is only at the perimeter so only the rebar in the footing can count as a CEE.
Pierre spelled it out
Also Pierre mentioned the vapor barrier that is often used under a slab.
It is my opinion that even without the vapor barrier under the slab that a slab, no matter how much rebar is in it will never qualify as an NEC CEE.