Because they’re independent, separate projects run by different people, and HM’s impl is simpler to write from the maintainers’ perspective. NixOS has more contributors and doesn’t need to hide from complexity where it’s useful.
Why would you want this? Rarely is a system service suitable to run as a user service, moreover with user services you get fewer options to work with.
I have a couple of python scripts running as services. I use system-manager for my non-NixOS server but would like to be able to run them as user services with home-manager on other machines.