CollectionPro Services LLC, a specialist in out-of-network reimbursement and Independent Dispute Resolution (IDR), is drawing attention to a case that illustrates a critical gap in the No Surprises Act arbitration process: a favorable IDR determination does not ensure that a provider will actually be paid. The case, Jason Weissler v. United Healthcare (Index No.: 652776/2026), involved a multi-location cosmetic surgery and dermatology group that won a $72,000 IDR award after UnitedHealthcare submitted an offer of $0. Despite the win, the award remained unpaid for months, prompting the provider to seek enforcement in the New York State Supreme Court, New York County, under CPLR Article 75.
The dispute centered on CPT 19318. 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. However, according to CollectionPro, the award went unpaid despite repeated reminders and demands. With CollectionPro's strategic guidance, the matter moved to court, where the petition sought enforcement of the $72,000 award plus statutory interest, the IDR entity fee, costs, and disbursements.
This case underscores a growing concern for out-of-network providers: an IDR win is not the final step. "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 reimbursement 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 having filed more than 10,000 out-of-network arbitrations with a 92% success rate, and it advances applicable arbitration costs while charging providers only after successful recovery.
For providers, the implications are significant. Winning an IDR determination is only half the battle; collecting the awarded amount can require additional legal steps. CollectionPro's involvement in this case highlights the need for specialized expertise to pursue payment after an IDR win. As Nissanoff noted, "Winning in IDR arbitration is one thing. Actually collecting the award is another and where experienced expertise is needed." The case serves as a reminder that providers must remain diligent throughout the recovery process, and that post-award support can be essential to securing the reimbursement they are owed.
