@skyboygames I'd say it counts in some way, since there's different levels of documentation. In this case, it might be easier to read and to navigate under given circumstances than the code. For example, I sometimes sit on the toilet reading documentation on my phone, and that's where I can't fire up a big IDE to navigate Unreal source code.
Though you're right, if there're no comments in that header file it still makes sense to generate it, but I wouldn't call it "docs".