This is NOT the case with HSAs. If you have an employer-sponsored HSA, the EMPLOYEE’S pretax contributions are NOT added back into income for FAFSA. That’s my point. Employee contributions are not treated as income on FAFSA.
However, tax-deductible HSA contributions ARE treated as untaxed income ONLY for self-employed workers. This has nothing to do with evolution of the HSA rules. It is highly (albeit unintentionally) discriminatory against older workers and female workers, who are way disproportionately represented among self-employed workers with individual HSAs.