Winning an Independent Dispute Resolution (IDR) determination under the No Surprises Act is often celebrated as the final step in securing fair 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 automatically translate into payment. The case, Jason Weissler v. United Healthcare (Index No.: 652776/2026), underscores a growing challenge: even after prevailing in federal IDR, providers may face unpaid awards that require further legal action to collect.
In the dispute, UnitedHealthcare submitted an offer of $0 for CPT 19318, 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 the applicable 30-calendar-day period. Yet, months passed without payment, despite repeated reminders and demands. With the support of CollectionPro Services LLC, a specialist in out-of-network reimbursement and IDR, the provider escalated the matter to the New York State Supreme Court, New York County, under CPLR Article 75. The petition sought enforcement of the $72,000 award, plus statutory interest, the IDR entity fee, costs, disbursements, and other appropriate relief.
This case illustrates a critical gap in 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 beyond IDR filing to encompass the entire recovery lifecycle. The firm offers open negotiation, IDR strategy, evidence development, IDR determination, award tracking, and post-award escalation and enforcement support. This end-to-end model is increasingly relevant as providers navigate the complex reimbursement environment created by the No Surprises Act. According to the company, it has filed more than 10,000 out-of-network arbitrations with a 92% success rate, and its model includes advancing applicable arbitration costs while charging providers only after successful recovery.
The implications for out-of-network providers are significant. A favorable IDR determination is only as valuable as the payment it ultimately secures. When payers fail to comply, providers must be prepared to pursue enforcement through the courts, a process that can be time-consuming and legally intricate. CollectionPro's involvement in this case highlights the importance of specialized expertise in post-award collections. As Nissanoff noted, "Winning in IDR arbitration is one thing. Actually collecting the award is another and where experienced expertise is needed." For providers, the key takeaway is that the reimbursement journey does not end with an IDR win. Having a partner that can maintain momentum through enforcement can make the difference between a paper victory and actual recovery.
