A recent case involving a multi-location cosmetic surgery and dermatology group has drawn attention to a critical gap in the out-of-network reimbursement process: winning an Independent Dispute Resolution (IDR) determination does not ensure payment. The provider prevailed in Federal IDR against UnitedHealthcare, securing a $72,000 award after the payer submitted an offer of $0. Yet months later, the award remains unpaid, forcing the provider to escalate the matter to the New York State Supreme Court.
The dispute centered on CPT 19318, a code for breast reduction surgery. UnitedHealthcare offered $0, while the provider sought $72,000. On February 18, 2026, the designated IDR entity selected the provider's full offer, declaring the provider the prevailing party. Under the No Surprises Act, any amount due following an IDR decision must be paid within 30 calendar days. Despite repeated reminders and demands, UnitedHealthcare failed to comply, leaving the provider with no choice but to pursue legal enforcement.
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 (Notice of Petition Jason Weissler v. United Healthcare Index No.: 652776/2026) 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.
This case underscores a growing concern for out-of-network healthcare providers: an IDR win is not the finish line. "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 recovery lifecycle, from open negotiation and IDR strategy to evidence development, award tracking, and post-award escalation and enforcement support. The company reports more than 10,000 out-of-network arbitrations filed and a 92% success rate, and its model includes advancing applicable arbitration costs and charging providers only after successful recovery. For providers navigating the complexities of the No Surprises Act, this end-to-end support can mean the difference between a paper victory and actual payment.
The implications are significant. As payers increasingly delay or ignore IDR awards, providers must be prepared to take legal action to collect what they are owed. CollectionPro's involvement in this case illustrates that expert guidance and persistent follow-through are essential to securing reimbursement. Without such support, even the most favorable IDR determination may remain an unfulfilled promise.
