No, it is not. You need to include an airspace beneath the combustion core floor so that heat can be carried away from the subfloor.
Insulation does not stop the flow of heat, it slows it down, and if a burn lasts long
enough, the heat will work its way through to the wooden supports. An airspace which allows free ventilation can short-circuit this and allow the heat to be carried out to the room air. You still want some insulation under the core to slow heat transfer as much as practical.