Lawful Residence for EU Students (CSI) - July Form AN Update

In September 2020 the Home Office updated its good character policy for naturalisation for EU nationals.

The new policy doubled the period of time, from five years to ten years, during which EU citizens who were students or self-sufficient in the UK during that period of time must have held comprehensive sickness insurance (CSI) or a European health insurance card (EHIC) issued by an EU country, in order to qualify for citizenship.

I can see the Home Office updated the AN form again earlier this month, and it now states the applicants must not at any time in the period of 5 years ending with the date of application be in the UK in breach of the immigration laws, which would include the CSI requirement.

However, a few pages down, it says:
you must assess whether an EU citizen who holds settled status has been here lawfully during their 3- or 5- year residential period prior to pre-settled status or settled status, by considering on the balance of probabilities whether they were here:
• as a qualified person (such as a worker, student, self-employed, self-sufficient, retired or incapacitated person)
• as the family member of such a person
Evidence of this can include API data or documents previously submitted to satisfy their lawful residence. Where appropriate, you must also be satisfied that the person was lawfully in the UK, with comprehensive sickness insurance (CSI).

Does it mean they will now be looking at whether EU citizens with settled status had CSI if they were students during the period 5 years before your settled status approval date + the time that has passed between your settled status approval and citizenship application?