Much easier to review for whomever wants to review it.
Case reports are descriptive not determinative and should be treated as such by other scholars. They are 'I saw this' not 'this is generalizably true'. They can (and often are) replicated or countered but they are not per se research as you are thinking about it. Whether it is fictitious or not, other scholars should be cautious in citing them as proof/evidence in papers that fit into the 'research' mold.
https://www.hhs.gov/hipaa/for-professionals/special-topics/d...
The IRB for a particular organization can impose additional restrictions.
What is stopping anyone from faking the data they use in their research papers?
Sure it might be verifiable but if the data was made to give the desired results, i.e. faked to be what is required for the paper.