You’re missing the point. It’s not about employer contributions to an HSA vs. employee contributions to that same HSA. Employee HSA contributions made through a cafeteria plan (payroll deductions) are not considered, while after tax employee contributions made to the same HSA account and taken as a tax deduction are considered by FAFSA. The federal tax implications are exactly the same either way and the contributed money can be used exactly the same way in either situation. It makes absolutely no sense for FAFSA to make a distinction here for federal student aid purposes.