Winning an Independent Dispute Resolution (IDR) determination under the No Surprises Act is often seen as the final step in securing reimbursement for out-of-network providers. However, a recent case handled by CollectionPro Services LLC illustrates that a favorable decision does not automatically translate into payment. The case, Jason Weissler v. United Healthcare (Index No.: 652776/2026), involved a multi-location cosmetic surgery and dermatology group that prevailed in Federal IDR with a $72,000 award for CPT 19318. UnitedHealthcare had 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 offer and declared the provider the prevailing party.
The IDR determination required any amount due to be paid within 30 calendar days. Yet, months passed without payment, despite repeated reminders and demands. This stalemate forced the provider to escalate the matter to the New York State Supreme Court, New York County, under CPLR Article 75. The petition sought enforcement and payment of the $72,000 award, along with statutory interest, the IDR entity fee, associated costs and disbursements, and other appropriate relief. The move underscores a growing concern: providers may win arbitration but still face significant hurdles in actually collecting the awarded funds.
CollectionPro, which supported the provider throughout the process, emphasizes that its role extends beyond IDR filing. "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."
The company's approach covers the full recovery lifecycle, including 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 complexities of the No Surprises Act. CollectionPro 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.
For out-of-network providers, the case serves as a cautionary tale. An IDR win is not a guarantee of payment. Payer noncompliance can require legal action, adding time and expense. As Nissanoff noted, "Winning in IDR arbitration is one thing. Actually collecting the award is another and where experienced expertise is needed." CollectionPro aims to help providers maintain momentum throughout the process instead of treating the arbitration decision as the finish line. Providers can learn more about CollectionPro's out-of-network reimbursement services and how they support post-award collections.
