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Coordination of benefits if you have two health plans

Last reviewed: August 26, 2026VerifiedOCS

In short

Act 161 of 2026 amends the Puerto Rico Health Insurance Code (Act 194-2011) and the Patient's Bill of Rights and Responsibilities (Act 194-2000) to solve a concrete problem: when a patient has two or more health plans, who coordinates which plan pays first and which covers what the first one did not? Before this law, there were disputes between providers and insurers over whose responsibility that was, and in practice the patient ended up paying out of pocket and requesting their own reimbursement. The law establishes that coordinating benefits is the joint responsibility of health insurance organizations or insurers, their intermediaries, and participating providers, with a 30-day maximum from when they receive all necessary information. It also sets that when a patient has a private plan plus the Government Health Plan of Puerto Rico, the Government Health Plan is always the secondary payer. If a provider refuses to coordinate, or an insurer or intermediary obstructs coordination without valid justification, the patient can file an administrative complaint with the Department of Health.

External link

Go to the official site

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What is it?

Coordination of benefits is the process by which, when you have more than one health plan, the primary plan pays the claim for medical services and the secondary plan pays the copays, deductibles and coinsurance the primary plan did not cover. Done right, you should not have to pay out of pocket or request your own reimbursement.

Who can do it?

It applies to any patient, insured person or consumer covered by two or more health plans, including someone who has a private health plan plus the Government Health Plan of Puerto Rico. It is your obligation to inform participating providers of all the health plans you hold.

Requirements

  • Informing and providing participating providers with information about all the health insurance plans you hold at the time you request or need a medical service.Verified against the official source
  • Confirming which is your primary plan and which is secondary. If you have the Government Health Plan of Puerto Rico plus a private plan, the Government Plan is always the secondary payer.Verified against the official source

Documents you need

Cost

This procedure has no cost.

Step by step

  1. Step 1: Give your provider information on all your plans

    Before or at the time of service, inform the participating provider about each health plan you have. Without that information, coordination cannot begin.

  2. Step 2: Do not accept the service being conditioned on you seeking your own reimbursement

    The law orders the Insurance Commissioner to prohibit by regulation participating providers from refusing to coordinate benefits, or from conditioning service on you handling the reimbursement with the insurer.

  3. Step 3: Remember the responsibility is shared, with a 30-day deadline

    Health insurance organizations, their intermediaries and participating providers have the joint responsibility to process the coordination of benefits, with a maximum of 30 days from when they receive all necessary information and documentation.

  4. Step 4: If coordination is obstructed, file a complaint

    If a provider refuses to coordinate, or an insurer, third-party administrator or intermediary obstructs or refuses without valid justification to cooperate, you can file an administrative complaint with the Department of Health under Article 17 of the Patient's Bill of Rights and Responsibilities.

Where to do it

The complaint is filed with the Department of Health. The Department will determine whether the matter falls under its jurisdiction or belongs to the Insurance Commissioner or the Health Insurance Administration (ASES), and will refer it accordingly.

How long it takes

Check the current processing time with the official agency.

What to do if something goes wrong

This law took effect immediately, but gives the Office of the Insurance Commissioner up to 90 days from its approval to draft the regulation with detailed parameters — for example, how billing and denials proceed between the primary and secondary plan. We did not read that regulation because, as of when we verified this guide, we did not find it published separately; what we describe here are the instructions the law gives the regulator, not settled rules with that level of detail. We also did not read Ley 38-2017 (the Uniform Administrative Procedure Act), which this law cites for the complaint process, so we do not describe that procedure step by step. This guide gives no deadline for resolving a complaint because the law does not set one. PRFácil does not process complaints or give legal advice.

Common mistakes

  • Paying the full deductible, copay or coinsurance and then requesting your own reimbursement from the second plan: the law places that responsibility on the provider and the insurers, not on you.
  • Assuming your private plan automatically pays first if you also have the Government Health Plan: the Government Plan is always the secondary payer, never the primary one.
  • Not informing your provider about all your plans: without that information, coordination cannot begin.
  • Accepting a provider conditioning service on you handling the reimbursement yourself: that is exactly what the law seeks to prohibit by regulation.

Frequently asked questions

Who is responsible for coordinating my benefits between two health plans?

It is a shared responsibility among health insurance organizations or insurers, their intermediaries, and participating providers. It is not your responsibility to chase your own reimbursement.

Which plan pays first if I have private insurance and the Government Health Plan?

Your private plan pays first. The Government Health Plan of Puerto Rico is always the secondary payer, without exception.

A provider refuses to coordinate my two insurance plans — what do I do?

You can file an administrative complaint with the Department of Health under Article 17 of the Patient's Bill of Rights and Responsibilities, which now expressly includes this situation as grounds for a complaint.

Official sources

These are the government pages this guide is based on.

Last verified

August 26, 2026

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