Sort of. But try not to think of it as such. QNE is the reading on the altimeter on landing with the subscale set 1013.2 hPa. In the Strathaven example you would be rounding out at 'FL19'. But best not to think of flight levels existing below the Transition Altitude. All you are looking for is, say, flying a circuit at approx 2900ft, final at approx 2400ft, landing at 1917ft etc. Needs special care in IMC! Use a RadAlt if you've got one…
Try it out in low pressure in VMC. The tables start at 979 hPa falling, so you should have at least 29 hPa or so to play with to set a real QFE on a second altimeter for comparison until you run out of subscale.