Winning a federal Independent Dispute Resolution (IDR) award does not ensure that a provider will actually receive payment, according to a recent case highlighted by CollectionPro Services LLC, a specialist in out-of-network reimbursement and IDR. The case, Jason Weissler v. United Healthcare (Index No.: 652776/2026), involved a multi-location cosmetic surgery and dermatology group that prevailed in IDR with a $72,000 award after UnitedHealthcare submitted an offer of $0. Despite the favorable determination, the award remained unpaid for months, prompting the provider to seek enforcement in the New York State Supreme Court, New York County, under CPLR Article 75.
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 IDR determination required any amount due following the decision to be paid within the applicable 30-calendar-day period. However, according to CollectionPro, the award remained unpaid for months despite repeated reminders and demands for payment. With CollectionPro's strategic guidance and active support, the matter proceeded to court, where 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.
This case underscores a critical gap in the No Surprises Act arbitration process: a favorable IDR determination is not the same as collecting the awarded reimbursement. "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 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, while its model includes advancing applicable arbitration costs and charging providers only following successful recovery.
For healthcare providers, the implications are significant. Winning an IDR case may be only the first step; collecting the award can require additional legal action, time, and resources. Providers should be aware that payers may delay or refuse payment even after a determination, and they may need to pursue enforcement through state courts. As out-of-network reimbursement becomes more complex, understanding post-award options is essential to securing rightful compensation. CollectionPro's case highlights that the real victory lies not just in the arbitration decision, but in actual payment.
