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Filing Information Notice (FIN) 2025-1 provides filing guidance for group filings being used for non-employer groups (NEG). This Tip drills down on the guidance provided in the FIN relative to updates to approved forms.  Filers are permitted to update approved group forms to make non-variable references to "employer" and "employee" variable to accommodate NEG terminology such as "policyholder", "contract holder",  "covered person", "certificate holder", "insured", "member", or such other terms to accurately reflect the identification of parties for specific groups.

If a company wishes to expand use of the approved forms and only a change to the terminology is needed, a Supporting Documentation Update (SDU) filing may be used. In the SDU filing, provide a revised explanation of variability that identifies and describes the new terms and when they will be used.  Additionally, submit specimen copies of the forms denoting the new variability under the Additional Supporting Documents tab and make sure to link all impacted filings as associated filings.  No other form changes are permitted beyond accommodating the NEG policyholder and certificateholder terminology. Consult FIN 2017-1 for additional guidance on SDU filings.