Winning a federal Independent Dispute Resolution (IDR) determination does not guarantee payment, as a recent case involving a multi-location cosmetic surgery and dermatology group demonstrates. The provider prevailed in IDR against UnitedHealthcare, securing a $72,000 award after the payer submitted an offer of $0. Yet the award remained unpaid for months, forcing the provider to escalate the matter to the New York State Supreme Court, New York County, under CPLR Article 75. The case, Jason Weissler v. United Healthcare (Index No.: 652776/2026), highlights a critical gap between winning an IDR decision and actually collecting the awarded funds.
The dispute involved CPT 19318. On February 18, 2026, the designated IDR entity selected the provider's full $72,000 offer, declaring the provider the prevailing party. Under the No Surprises Act, any amount due following the determination must be paid within 30 calendar days. However, despite repeated reminders and demands, UnitedHealthcare did not remit payment. With strategic guidance and active support from CollectionPro Services LLC, a specialist in out-of-network reimbursement and IDR, the provider filed a petition in the New York Supreme Court seeking enforcement and payment of the $72,000 award, plus statutory interest, the IDR entity fee, costs, disbursements, and other appropriate relief.
"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."
This case illustrates a broader challenge for out-of-network providers: even a decisive IDR win can be rendered meaningless if the payer refuses to pay. CollectionPro's approach extends across the entire 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, and its model includes advancing applicable arbitration costs and charging providers only after successful recovery.
For providers navigating the increasingly specialized reimbursement environment under the No Surprises Act, the key takeaway is that IDR victory is not the finish line. As this case shows, pursuing the actual payment can require further legal action. CollectionPro's involvement demonstrates how specialized post-award support can help providers maintain momentum and pursue the funds they are owed, rather than treating the arbitration decision as the end of the process.
