A couple of years back, the starting Alabama QB was not on scholarship. Apparently he was from a well to do family who had donated significant sums in the past, so they agreed to foot his bill freeing up a spot for another player.
This looks like a potential item for abuse to me. Some Big Donor could give said family the money for college and it wouldn't be a scholarship, in theory. He'd have to pay gift tax to be legal.
Imagine having ten starters not on scholarship counting against that 85.