A multi-location cosmetic surgery and dermatology group won a $72,000 federal Independent Dispute Resolution (IDR) award against UnitedHealthcare, but when the payment was not made, the provider had to take 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), illustrates a critical gap in the No Surprises Act arbitration process: a favorable determination does not guarantee payment.
According to CollectionPro Services LLC, the dispute involved 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 determination required payment within the applicable 30-calendar-day period, but the award remained unpaid for months despite repeated reminders and demands. With CollectionPro’s strategic guidance, the provider filed a petition seeking enforcement and payment of the $72,000 award, along with statutory interest, the IDR entity fee, associated costs and disbursements, and any 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.”
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 its model includes advancing applicable arbitration costs and charging providers only following successful recovery. For more information, visit CollectionPro.
The case underscores a growing concern for out-of-network providers: winning an IDR determination is only the first step. As payers increasingly delay or refuse payment, providers must be prepared to pursue legal enforcement to secure the reimbursement they are owed. CollectionPro’s involvement demonstrates that post-award support can be essential to ensuring that arbitration victories translate into actual payment.
