Unfortunately, what I have described is not speculation but reality. I know High School coaches who have been told this by multiple PL coaches. The league does not want to have to differentiate between who was recruited and who is a “true” walk-on. Understandably, that could be a very grey area.
The NCAA manual is available online. The NCAA restrictions for FCS football are 63 scholarships and 85 “counters”. So you can only have 85 guys receiving ANY form of aid. You can still only have 63 football scholarships. But in theory you could have 63 full scholarships and 22 need based financial aid players on the roster. Anyone on a football scholarship (even partial) is a counter. I believe an athlete on non-athletic fin aid is not a counter until the athlete plays. I know an athlete who does not receive any fin aid is never a counter regardless of whether or not he plays.
Just for sake of example, lets say Delaware has 63 full scholarship players and 22 need based players who all receive 1/2 tuition in fin aid which is perfectly legal by NCAA rules. Under PL rules, they would have 74 scholarship equivalencies well above the 60 allowed.
Just another disadvantage PL programs face.