HSA is our biggest impediment to not filing 1040. As far as I can see, either contributing or withdrawing from our HSA triggers need to file 1040.
I'm still looking for a new way to qualify - in the past we qualified for free/reduced lunches, when we were a family of 7 at home. Our income has increased while the kids have gone off to college, one by one, reducing our family size. The advantage of qualifying due to free/reduced lunches is that it can be used to qualify for up to 3 years based on the way the FAFSA asks about years received. I.e., we last had reduced lunch DS4's senior year, 2015-16. The FAFSA for his freshman college year asked if we qualified in 2014 or 2015. Yep. Next FAFSA asks for 2015/2016. Yep. Next year asks for 2016/2017. Yep. So only his 4th year FAFSA won't be eligible.
Actually, we can't qualify for the auto EFC=0 anymore, since they retroactively raised the AGI level from $32k to $23 a few years ago. We have qualified for the Simplified Needs Test to ignore assets, though. Until recently, though, we've hit zero or close to zero EFC through calculations instead. This is getting harder now, though. DS2 was considered in family size for FAFSA purposes until he hit age 24 this year. DD3 may attend grad school, knocking her off our family size for FAFSA as well. So we'll drop from family size 6 to 4 in quick succession, as our gross income creeps up (lots more going to retirement, but gets added back to "available income").
I'm most concerned for DS5 - he will appear to be an only child, just as our income peaks after years of undersaving on a low income raising 5 kids. I'm running the numbers on getting to FIRE just as we hit the tax year for his first FAFSA. Health insurance is the big unknown. He graduates 2023, so file FAFSA Oct 2022 with 2021 tax return. Another option is DH retires and I keep on at my part-time job, but again health insurance is the issue (I have no benefits). I keep watching how the FAFSA rules evolve