A multi-location cosmetic surgery and dermatology group secured a $72,000 Independent Dispute Resolution (IDR) award against UnitedHealthcare, but the payer's failure to pay has pushed the dispute into the New York State Supreme Court, New York County. The case, Jason Weissler v. United Healthcare (Index No.: 652776/2026), underscores a critical gap in the No Surprises Act arbitration process: winning an IDR determination does not guarantee timely payment.
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. Under the IDR determination, any amount due was to be paid within 30 calendar days. However, months passed without payment despite repeated reminders and demands, according to CollectionPro Services LLC, a specialist in out-of-network reimbursement and IDR that supported the provider.
With CollectionPro's strategic guidance, the matter proceeded to the New York State Supreme Court under CPLR Article 75. The petition seeks 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. The case highlights the distinction between receiving a favorable IDR determination and actually collecting the awarded funds.
"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 entire out-of-network recovery lifecycle, from open negotiation and IDR strategy to evidence development, award tracking, and post-award escalation and enforcement support. This end-to-end model is increasingly relevant as providers navigate the complexities of the No Surprises Act. The company reports more than 10,000 out-of-network arbitrations filed and a 92% success rate, while advancing applicable arbitration costs and charging providers only after successful recovery.
The implications for healthcare providers are significant. Many may assume that a favorable IDR decision automatically results in payment, but this case demonstrates that enforcement may require additional legal action. For payers, it signals that non-compliance with IDR awards can lead to court involvement and additional costs. For the broader industry, it highlights the need for robust post-award processes to ensure providers receive the reimbursement they are owed.
CollectionPro's involvement in this case exemplifies its commitment to supporting providers beyond the arbitration phase. As Nissanoff noted, "Winning in IDR arbitration is one thing. Actually collecting the award is another and where experienced expertise is needed." Providers seeking to navigate the post-award landscape can learn more about CollectionPro's out-of-network reimbursement services.
