A recent case involving a multi-location cosmetic surgery and dermatology group has drawn attention to a critical gap in the out-of-network reimbursement process: winning an Independent Dispute Resolution (IDR) determination does not guarantee payment. The case, Jason Weissler v. United Healthcare (Index No.: 652776/2026), resulted in a $72,000 IDR award against UnitedHealthcare, but when the award remained unpaid for months, the provider turned to New York State Supreme Court to enforce it.
The dispute centered on CPT 19318, a code for breast reduction surgery. 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. Under the IDR determination, any amount due was required to be paid within the applicable 30-calendar-day period. However, despite repeated reminders and demands, the award went unpaid, according to CollectionPro Services LLC, a specialist in out-of-network reimbursement and IDR that supported the provider.
With CollectionPro's strategic guidance, the matter proceeded to the New York State Supreme Court, New York County, under CPLR Article 75. The petition sought enforcement and payment of the $72,000 IDR award, along with statutory interest, the IDR entity fee, associated costs and disbursements, and any other appropriate relief. The case illustrates that a favorable IDR determination is not always the end of the reimbursement process.
"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."
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 following successful recovery.
This case matters because it highlights a systemic issue: even when providers prevail in federal IDR under the No Surprises Act, collecting the awarded amount can require further legal action. For out-of-network providers, the implications are significant—unpaid awards can strain cash flow and undermine the intended benefits of the arbitration process. CollectionPro's involvement demonstrates that post-award enforcement is becoming an essential part of revenue recovery. Providers can learn more about CollectionPro's services at https://www.collectionpro.com.
As the healthcare industry continues to navigate the complexities of the No Surprises Act, this case serves as a reminder that winning an IDR arbitration is only one step. Pursuing payment after a favorable determination is equally important, and providers may need specialized support to ensure they receive the reimbursement they have been awarded.
