When a multi-location cosmetic surgery and dermatology group won a $72,000 Independent Dispute Resolution (IDR) award against UnitedHealthcare, it seemed like a clear victory. UnitedHealthcare had submitted an offer of $0 for CPT 19318, while the provider sought $72,000. On February 18, 2026, the IDR entity selected the provider's full offer, declaring the provider the prevailing party. The determination required payment within 30 calendar days. Yet months passed without payment, despite repeated demands. The case, Jason Weissler v. United Healthcare (Index No.: 652776/2026), then moved to the New York State Supreme Court, New York County, under CPLR Article 75, seeking enforcement of the award plus statutory interest, the IDR entity fee, and costs.
This scenario is becoming increasingly common for out-of-network providers. Winning an IDR determination does not guarantee prompt payment. As David Nissanoff, spokesperson for CollectionPro, explains: "Providers should not have to assume that their work is finished simply because they received a favorable IDR determination. The real objective is not just to win arbitration. It is to pursue the reimbursement the provider has been awarded." CollectionPro, a specialist in out-of-network reimbursement and IDR, provided strategic guidance and active support in this case, illustrating the gap between a favorable decision and actual payment.
The implications for providers are significant. Under the No Surprises Act, IDR is intended to resolve payment disputes efficiently, but enforcement mechanisms are not automatic. Providers must be prepared to escalate unpaid awards to court, a process that requires additional legal steps and costs. CollectionPro's approach spans the entire recovery lifecycle: open negotiation, IDR strategy, evidence development, IDR determination, award tracking, and post-award escalation and enforcement support. With over 10,000 out-of-network arbitrations filed and a reported 92% success rate, the company advances arbitration costs and charges providers only after successful recovery. More information about their services is available at https://www.collectionpro.com.
For providers, the key takeaway is that an IDR win is not the end of the road. As Nissanoff notes, "The real objective is not just to win arbitration. It is to pursue the reimbursement the provider has been awarded." Without dedicated post-award follow-up, even strong IDR victories can languish. CollectionPro's model emphasizes maintaining momentum, ensuring that arbitration decisions lead to actual payments. This case serves as a reminder that reimbursement recovery requires vigilance beyond the initial determination, and providers should evaluate their processes for tracking and enforcing awards to avoid similar delays.
