When is a complaint written and who is it sent to?
The Supervision Service's Instruction defines a complaint as any written or oral statement in which a consumer expresses dissatisfaction with the insurer or its service. The Instruction divides such statements into categories, and the first category covers exactly what this page is about: a statement that concerns the insurer's decision on reimbursement and asks for it to be changed in full or in part, for reasons to be given, or for the decision to be reviewed.
It is important to distinguish two things. The initial reimbursement claim is the application in which you first ask for the cost to be covered; a complaint challenges a decision that has already been made. A complaint is written when:
- the company has refused reimbursement entirely;
- it has paid less than you claimed and the difference is not explained, or the explanation does not match the policy;
- the refusal was communicated without reasons, only by a phone call or a short SMS;
- no decision has been made for a long time and you are not told why.
The addressee is the insurer, or more precisely its independent unit responsible for handling complaints. Under the Instruction, the company must publish its complaints procedure on its website and make a standard written complaint form available, so look for the channel and the form on the company's website first. If the refusal comes from a state programme, it is not an insurance dispute and is challenged through an administrative complaint.
What deadlines apply?
| Stage | Deadline | Basis |
|---|---|---|
| Notifying the insurer of an insured event | As soon as you learn that the event has occurred; the exact form and deadline are set by the policy | CC, Art. 814 |
| Payment of reimbursement | After the insured event is established and the amount of compensation is determined; the exact deadline is set by the policy | CC, Art. 814 |
| Response to a written complaint | No more than 30 calendar days after receipt, with reasoned justification | Instruction, Art. 6 |
| Confirmation of receipt of an electronic complaint | On receipt, electronically | Instruction, Art. 6 |
| Claim in court | The general limitation period for a contractual claim is three years, from the moment you learn of the breach of your right | CC, Arts. 129-130 |
CC: Civil Code of Georgia; Instruction: the Instruction on the Protection of Consumer Rights approved by Order No. 18 of the State Insurance Supervision Service of 3 April 2017.
The policy's deadlines for notification and for submitting a claim are often shorter than families think. Under the Instruction, the insurer must tell you about this form and these deadlines at the offer stage and attach to the contract an insert titled “Key terms of the contract”. Read this sheet first: it says within how many days and through which channel you had to notify the company.
A practical tip: before writing the complaint, put together a timeline on one sheet. Note the day treatment began, the date you notified the company, when you submitted the reimbursement claim, and when and in what form you received the refusal. This shows at a glance whether you missed any deadline yourself and where the company was late. The timeline will serve as the basis for the factual part of the complaint and will also save a lawyer's time later.
How to build the argument: what does the law say?
A strong complaint sets the reason for the refusal against the text of the policy and a specific legal provision. The typical reasons for insurance refusals and ways of reading a policy are described in detail on the insurance disputes page; here we have gathered the provisions we use most often in the text of a complaint.
Late notification
Under Article 814 of the Civil Code, the insurer cannot rely on a condition that releases it from its obligation when the notification requirement is breached, if the breach did not substantially harm its interests. In other words, the mere fact that you called the hotline the next day is not enough for a refusal: the company has to show what harm the delay caused.
Pre-existing conditions and the questionnaire
Under Article 808, when the contract is concluded the policyholder informs the insurer of the material circumstances known to them, and anything the insurer asks about in writing, clearly and unambiguously, is also considered material. Under the same article, the contract cannot be terminated if the insurer knew about the undisclosed circumstance or the policyholder was not at fault for failing to disclose it. Article 812 adds that withdrawal after the insured event does not release the insurer from its obligation if the undisclosed circumstance had no influence on the occurrence of the event.
An exclusion you were not told about
Under the Instruction, exclusions and all conditions that release the insurer from reimbursement must be printed in bold on the information sheet, and the burden of proving that the consumer was fully informed of the terms lies with the insurer. If an exclusion was hidden deep in the contract in small print, be sure to point this out in your complaint.
An argument must always be specific: the clause number, the date, the document. A general phrase such as “the refusal is unfair” tells the reviewing unit nothing.
What should you attach to the complaint?
Number the attachments and list them at the end of the complaint, so that the company cannot claim it never received a document. Attach a copy of each one and keep the originals yourself.
- the company's written refusal or the reimbursement calculation you disagree with;
- the policy, the “Key terms of the contract” and the annex containing the clause cited as grounds for the refusal;
- medical documents: Form IV-100/a, the discharge summary, imaging and test reports and, if the case concerns an emergency, a letter from the treating doctor explaining why the treatment was necessary;
- financial documents: a detailed invoice, the payment receipt, a bank statement;
- proof of notification: the date of the hotline call, the claim number, emails;
- a power of attorney, if a family member signs the complaint on the patient's behalf; how to prepare one is explained on the power of attorney template page.
A Georgian insurer usually asks for a foreign clinic's invoice and discharge summary together with a Georgian translation. We translate these documents following the procedure described on the financial documents and discharge summary translation pages.
Complaint template for an insurance company
Copy the text, fill in the fields and delete any sentences you do not need. If the company has its own standard form, fill that in and attach this text as an annex. You can send this English text directly to a foreign insurer, but a Georgian insurer needs the letter in Georgian: the Georgian version of this page (language switch at the top) has the original text to copy.
To: [full name of the insurance company], complaints handling unit
Address or email: [company address or email for complaints]
Applicant: [first name and surname], personal number [personal number], address [address], telephone [telephone], email [email]
Insured person: [insured person's full name, if different from the applicant]; basis of representation: [power of attorney details]
Policy: [policy number], period of cover [start and end dates]; reimbursement claim number: [claim number]
Complaint requesting review of a refusal to reimburse
On [date] I applied to the company for reimbursement of the cost of [brief description of the service, clinic and dates], totalling [amount and currency]. I notified the company of the insured event on [date and channel: hotline, email, app].
On [date of decision] the company [“refused reimbursement” or “reimbursed only ... of the amount”], giving as its reason [reason for the refusal and policy clause, as stated in the letter].
I do not agree with this decision for the following reasons:
1. [first argument: which policy clause covers the event and why];
2. [second argument: why the cited exclusion or condition does not apply];
3. [third argument: a legal provision, for example Article 814 of the Civil Code, if the refusal is based on late notification].
In view of the above, I ask you to:
a) review the decision of [date of decision] and reimburse me [amount claimed and currency];
b) if you do not grant the claim in full or in part, inform me in writing of your reasoned justification, citing the specific clause of the policy;
c) provide me with the case materials, including any expert opinion you used, and a description of the procedure and methodology by which you examined the claim.
Please send your response to [email or postal address] within the deadline set by the Supervision Service's Instruction.
Attachments:
1. [company letter or calculation];
2. [policy and key terms];
3. [medical documents];
4. [invoice and proof of payment];
5. [power of attorney, if needed].
[date]
[signature]
How to fill in and send the complaint
Get the exact wording of the refusal
If you were refused orally, first ask for a written decision. You need this text because the policy clause has to be quoted word for word in the complaint.
Compare it with the policy
Open the annex the company refers to and find the definition of the insured event. Write a separate point for each argument.
State the amount
In your demand, give a specific amount and currency and, for a partial refusal, a calculation of the difference as well, taking the excess and co-payment into account.
Send it in a way that leaves a trail
Use the company's official channel: email, or delivery to the office with a registration number. For an electronic complaint, keep the confirmation of receipt, because the 30 days run from receipt of the complaint.
Note the deadline
Mark day 30 in your calendar. If no response arrives or it gives no reasons, you have grounds to move on to the next stage.
Common mistakes that weaken a complaint
- Emotional text instead of facts. The reviewer checks clauses and documents; accusations and general judgements distract attention from the main argument.
- A complaint without a demand. If it does not say exactly what you are asking for and what amount, the company can reply that the decision stands and close the correspondence.
- Sending originals. Keep the originals yourself: you will need them at the court stage too.
- Repeating the same complaint. Under the Instruction, if the insurer has already examined a complaint from the same consumer on the same claim, its complaint-handling obligations no longer apply. So submit all your arguments and documents in your very first complaint.
- Relying on an oral promise. If an operator promises that the matter will be reviewed, have this confirmed in writing and keep to your own deadlines anyway.
What if the response does not satisfy you?
If the company has rejected your complaint or has not replied within 30 days, you have two routes, which are not mutually exclusive. The first is the State Insurance Supervision Service, which monitors insurers' compliance with the law and consumer protection rules. Under the Instruction, the company must, at the Service's request, submit its records of the complaint, the reasoned justification and any expert opinion. The Service's role is supervisory; a binding decision ordering payment is, as a rule, made by a court.
The second route is a lawsuit seeking an order for payment of the insurance reimbursement. Under Article 129 of the Civil Code, the limitation period for a contractual claim is three years and, under Article 130, it starts from the moment the person learned or should have learned of the breach of their right. Check the policy's dispute resolution clause separately: it may specify the competent court or another dispute resolution procedure. Advocat.Ge lawyers prepare the lawsuit and represent you as part of the insurance disputes service.
If the remaining treatment costs cannot wait until the dispute is over, consider other sources in parallel; the surgery funding guide explains in what order to approach them.
Frequently asked questions about insurance complaints
How long does an insurance company have to respond to a complaint?
Under the Instruction of the State Insurance Supervision Service, the insurer examines a complaint within a reasonable time and informs you of the outcome of a complaint submitted in writing no later than 30 calendar days after receiving it. The response must contain a reasoned justification and, where possible, an offer to settle the dispute. The deadline runs from receipt of the complaint, so keep the registration number or the electronic confirmation. If 30 days have passed without a response, record this fact in writing: you will need it at the Supervision Service and court stages.
Do I have to pay to file a complaint?
The Instruction requires the insurer to make a standard written complaint form available and to provide all documents accompanying the policy at the consumer's request at no extra charge. The Instruction does not provide for any fee for examining a complaint. Your costs are usually limited to copies of documents, translation where needed and, if you choose, a lawyer's services. In a simple case, for example when the refusal is based on a missing document, you can write the complaint yourself using this template. In a complex case, especially a dispute about a pre-existing condition, it is better to have a lawyer check the text.
The company refused me orally. What should I do?
An oral refusal is a weak basis for an appeal, because it is not clear which clause it relies on. First ask in writing for the decision and its reasons, with a reference to the specific clause of the policy. Under the Instruction, this is also a complaint, because a request for the reasons behind a reimbursement decision falls into the first category. So you can use this template even if you do not yet have any arguments: keep only the facts and points b) and c) of the demand, and write a reasoned complaint once you have received the response.
Can a family member file a complaint on the patient's behalf?
Yes, if they are authorised to do so. This is usually a notarised power of attorney that names the specific insurer and policy and sets out the right to submit the reimbursement claim and the complaint and to receive the response and the case materials. Decide separately whether the representative may receive the money into their own account. If the insured person is a minor, the complaint is usually signed by a parent or legal representative, who attaches a document proving the relationship. The template has a separate field for the basis of representation.
Does the template guarantee that I will get my money back?
No. The template only gives you a structure, so that the company understands your claim correctly and gives you a reasoned response. The outcome depends on the text of the policy, the documents and the real grounds for the refusal. If the policy clearly does not cover the service or the limit really has been used up, a complaint rarely changes the decision. If, however, the refusal rests on vague wording, a missing document or a minor delay in notification, the complaint has a real basis. A lawyer will compare the refusal letter with the policy and tell you whether it is worth continuing the dispute.
Sources and official pages
- Civil Code of Georgia (Articles 129-130, 799, 808, 812, 814): matsne.gov.ge/ka/document/view/31702 (accessed 2026-10-12)
- Order No. 18 of the State Insurance Supervision Service of 3 April 2017, Instruction on the Protection of Consumer Rights (Articles 2-6): insurance.gov.ge/files/ShowFiles?id=4881f5b7-4133-47d6-9549-0801fc4ea420 (accessed 2026-10-12)
- State Insurance Supervision Service of Georgia: insurance.gov.ge/ka (accessed 2026-10-12)