When an independent dispute resolution (IDR) entity awarded a multi-location cosmetic surgery and dermatology group $72,000 against UnitedHealthcare, the provider might have expected timely payment. Instead, the award remained unpaid for months, forcing the provider to seek enforcement in the New York State Supreme Court, New York County, under CPLR Article 75. The case, Jason Weissler v. United Healthcare (Index No.: 652776/2026), underscores a critical gap in the No Surprises Act arbitration process: winning an IDR determination does not guarantee reimbursement.
The dispute centered on CPT 19318. UnitedHealthcare submitted an offer of $0, while the provider submitted an offer of $72,000. On February 18, 2026, the designated IDR entity selected the provider's full $72,000 offer and declared the provider the prevailing party. The determination required payment within 30 calendar days. However, according to CollectionPro Services LLC, a specialist in out-of-network reimbursement and IDR, the award went unpaid despite repeated reminders and demands. CollectionPro provided strategic guidance and active support as the matter proceeded to court, where the petition sought enforcement of the $72,000 award plus statutory interest, the IDR entity fee, costs, and disbursements.
"Providers should not have to assume that their work is finished simply because they received a favorable IDR determination," said David Nissanoff, spokesperson for CollectionPro. "The real objective is not just to win arbitration. It is to pursue the reimbursement the provider has been awarded. When payment remains unresolved after a favorable determination, providers need to understand what options may be available for the next stage of recovery."
The case illustrates a broader challenge for out-of-network providers: even after prevailing in federal IDR, collecting the award can require additional legal action. CollectionPro's approach extends across the recovery lifecycle, including open negotiation, IDR strategy, evidence development, IDR determination, award tracking, and post-award escalation and enforcement support. The company reports more than 10,000 out-of-network arbitrations filed and a 92% success rate, while advancing applicable arbitration costs and charging providers only after successful recovery.
For providers, the implications are significant. A favorable IDR determination is only as valuable as the payment it ultimately produces. As payers increasingly submit low or zero offers and delay payment, providers must be prepared to pursue enforcement. CollectionPro's involvement in this case highlights the importance of end-to-end support that does not treat the arbitration decision as the finish line. More information about CollectionPro's services is available at https://www.collectionproservices.com/.
