Sure, in the same way that software engineering isn't engineering, if you want to be pedantic about the term "engineering".
Software engineering is. The problem is most people think they are software engineers simply because a company makes such title for a job. If that is accepted, then why not call janitors as senior principal custodial enginner.
Software engineering is a type of engineering, but very few programmers actually do or even understand software engineering. Believe me, I know: I have hired and fired a lot of them.
No, software engineering is. Writing prompts to a chat bot is just being a user of that software