There is no requirement to create an concrete encased electrode if one does not exist. If there a vapor barrier under concrete that would otherwise qualify for use as a CEE, you just don't have a CEE and will have to use other electrodes to satisfy the requirement for a grounding electrode.
Informational Note: Concrete installed with insulation, vapor
barriers, films or similar items separating the concrete
from the earth is not considered to be in ?direct contact?
with the earth.
Now does that negate?:
250.50 Grounding Electrode System.
All grounding electrodes
as described in 250.52(A)(1) through (A)(7) that are
present at each building or structure served
shall be bonded
together to form the grounding electrode system. Where
none of these grounding electrodes exist, one or more of
the grounding electrodes specified in 250.52(A)(4) through
(A)(8) shall be installed and used.
The exception does not apply.
Exception: Concrete-encased electrodes of
existing buildings
or structures shall not be required to be part of the
grounding electrode system where the steel reinforcing bars
or rods are not accessible for use without disturbing the
concrete.