We just installed a new bath in part of our house where the plumbers had to jackhammer up the floor and install pipes etc. We had to have it inspected and gravel with a small layer of concrete would have never passed inspection at all in my city. I would think it would not be the best idea.
i am not a contractor or anything like that, just going based on ispection that was done on my project. Its called a foundation for a reason. The foundation is very important no matter how stable the shower pan may seem it should still be supported will underneath.
In my opinon.