When a multi-location cosmetic surgery and dermatology group won a $72,000 Independent Dispute Resolution (IDR) award against UnitedHealthcare, the victory initially appeared decisive. UnitedHealthcare had 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 any amount due to be paid within the applicable 30-calendar-day period. Yet the award remained unpaid for months despite repeated reminders and demands for payment.
The case, Jason Weissler v. United Healthcare (Index No.: 652776/2026), illustrates a growing concern for out-of-network healthcare providers: winning an IDR determination does not necessarily mean the reimbursement process is over. 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 any other appropriate relief.
This development matters because it underscores a critical distinction between receiving a favorable IDR determination and actually collecting the awarded funds. Many providers may assume that a prevailing determination automatically triggers payment, but as this case shows, payers can delay or fail to comply, forcing providers to pursue further legal action. The implications for the healthcare industry are significant: out-of-network providers must be prepared for post-award enforcement, which can involve additional time, costs, and legal complexity.
"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 providers, the key takeaway is that an IDR win may only be the beginning. Without robust post-award collection efforts, even the most favorable determinations can remain unpaid. As this case demonstrates, enforcement through state courts may become necessary, and specialized expertise can help providers maintain momentum throughout that process instead of treating the arbitration decision as the finish line.
