That is interesting, because that is not the way it is presented here by my local AHJs.
Part of the issue is, like I said, California building code requires rebar in the footings. Therefore it must be used as a CEE, unless it is disqualified because of a vapor barrier or insulation.
When we get a footing/pre-pour inspection, for rebar size and placement, setback, footing size and depth, etc., the inspectigator checks for the presence of a CEE. I’ve built several buildings in the last few years, since that became a requirement, and every single one without an exception, the inspector has looked for a CEE.
But like I said, that is probably because we can’t, don’t, and won’t, build without rebar here in California.
Edit to add: Virtually every set of engineered plans I get has a CEE called out as well, so that makes it a requirement, but even the ones that didn’t it was still checked for by the inspector.