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 offered $0 for CPT 19318, while the provider sought $72,000. On February 18, 2026, the IDR entity selected the provider's full offer and named 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, costs, and disbursements.
This sequence illustrates a growing problem for out-of-network providers: a favorable IDR determination does not guarantee reimbursement. CollectionPro Services LLC, a specialist in out-of-network reimbursement and IDR, supported the provider through this post-award phase. According to David Nissanoff, spokesperson for CollectionPro, "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." His comments underscore a systemic gap: payers may delay or ignore awards, forcing providers into costly enforcement actions.
The implications extend beyond one case. Under the No Surprises Act, IDR is meant to resolve payment disputes efficiently, but without enforcement, the process can leave providers uncompensated. CollectionPro's approach spans the entire recovery lifecycle—open negotiation, IDR strategy, evidence development, award tracking, and post-award escalation. The company reports over 10,000 out-of-network arbitrations filed and a 92% success rate, advancing arbitration costs and charging providers only after successful recovery. For more information, visit CollectionPro.
This case signals that providers must plan for collection from the outset. Winning an IDR award is only the first step; securing payment often requires legal enforcement. As payers continue to test the boundaries of compliance, providers need partners who can navigate both arbitration and the courts. CollectionPro's involvement in this New York Supreme Court petition demonstrates that post-award support is not optional—it is essential for ensuring that IDR victories translate into actual revenue.
