They could be.
LLMs are used for so many NLP purposes, but sometimes, we really need to sharpen an LLM's saw to focus solely on "tool calling", and a lot of tool calling involves NER. Without the fine tuning, you get lots of "hallucinations" (bad results).
That said, a lot of off-the-shelf LLMs have already been trained to handle NER just fine, and fine-tuning is not really that necessary.