Winning an Independent Dispute Resolution (IDR) determination under the No Surprises Act is often seen as the final step in securing reimbursement for out-of-network providers. However, a recent case involving a multi-location cosmetic surgery and dermatology group demonstrates that a favorable IDR decision does not guarantee payment. The case, Jason Weissler v. United Healthcare (Index No.: 652776/2026), highlights a growing challenge: even after prevailing in federal IDR, providers may face unpaid awards and must pursue further legal action to collect.
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. The IDR determination required payment within 30 calendar days. Yet, despite repeated reminders and demands, the award remained unpaid for months. This is where the case moved beyond a conventional IDR victory.
With strategic guidance and active support from CollectionPro Services LLC, a specialist in out-of-network reimbursement and IDR, 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 other appropriate relief. This step illustrates the distinction between receiving a favorable IDR determination and actually collecting the awarded amount.
“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 to out-of-network reimbursement extends across the recovery lifecycle rather than focusing solely on arbitration filings. Its process can include open negotiation, IDR strategy, evidence development, IDR determination, award tracking, and post-award escalation and enforcement support. This end-to-end approach is particularly relevant as providers navigate an increasingly specialized reimbursement environment under the No Surprises Act.
The company reports more than 10,000 out-of-network arbitrations filed and a 92% success rate. Its model includes advancing applicable arbitration costs and charging providers only following successful recovery. For providers, the key takeaway is that an IDR win is not the finish line. As this case shows, pursuing payment after a favorable determination may require additional legal steps. CollectionPro aims to help providers maintain momentum throughout that process instead of treating the arbitration decision as the end. The case is a reminder that winning in IDR arbitration is one thing; collecting the award is another, and it often requires experienced expertise.
