I was going to say skin friction as the most likely option, as well.
Some other possibilities:
1) It could be there to control weak axis bending in a beam. It can certainly be used for strong axis moment as well, it's just not as effective for that.
2) If the beam has significant axial load, they may be detailing it more like a column. I'm thinking of beams that are used as chords or collectors.
3) Maybe they're concerned about crack control. I think this is one of the reasons for the skin friction requirements, but I'm not certain.
4) Goofy detailing reasons. Like you want some bars to be continuous through a joint, but the ones at the top and bottom are in a very congested area. Though I would think this would be localized to a specific joint.
5) If you want to attached things to the side of the beam with anchors or such, or you have some penetrations. In those cases, you might want some extra reinforcement around throw some bars in there.... Though I would think this would be very localized.