No, question 94.a. says –
Payments to tax-deferred pension and retirement savings plans (paid directly or withheld from earnings), including, but not limited to, amounts reported on the W-2 forms in Boxes 12a through 12d, codes D, E, F, G, H and S. Don’t include amounts reported in code DD (employer contributions toward employee health benefits).
(emphasis in bold added)
Funds obtained from a HELOC and contributed to a tax-deferred retirement plan resulting in an above-the-line deduction would be paid directly to the retirement plan. Such a payment would need to be reported on FAFSA. It doesn’t matter where the money comes from, and besides, all money is fungible. What matters is there would be a tax-advantaged payment to a qualified retirement savings plan.