Winning a federal Independent Dispute Resolution (IDR) determination does not guarantee that an out-of-network provider will actually receive the awarded reimbursement. That reality is at the center of a recent case involving a multi-location cosmetic surgery and dermatology group that prevailed in IDR with a $72,000 award against UnitedHealthcare, only to find the payment remained unresolved after months of repeated reminders and demands.
The dispute involved CPT 19318. UnitedHealthcare 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 $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. However, the award remained unpaid, turning a clear IDR victory into a collection problem.
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. The case is identified as Notice of Petition Jason Weissler v. United Healthcare, Index No.: 652776/2026.
This development underscores a growing concern for out-of-network healthcare providers: a favorable IDR determination is not necessarily the end of the reimbursement process. "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 to out-of-network reimbursement 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 focuses specifically on out-of-network revenue recovery, including payer negotiations, appeals, IDR support, aged accounts receivable as well as post-award collections. CollectionPro 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 more information, visit CollectionPro.
The implications for providers are significant. An IDR award that goes unpaid can strain cash flow and undermine the intended protections of the No Surprises Act. Enforcement actions like the one in New York Supreme Court signal that providers may need to pursue judicial remedies to collect what they are owed. As this case demonstrates, the distinction between winning an IDR determination and actually collecting the award is critical, and bridging that gap may require specialized post-award support.
