Winning a federal Independent Dispute Resolution (IDR) case does not ensure that a provider will actually receive the awarded reimbursement, as shown by a recent case involving a multi-location cosmetic surgery and dermatology group. The provider prevailed in IDR against UnitedHealthcare, securing a $72,000 award after the payer submitted an offer of $0. Yet the award remained unpaid for months, forcing the provider to escalate the matter to the New York State Supreme Court, New York County, under CPLR Article 75. The case, Notice of Petition Jason Weissler v. United Healthcare Index No.: 652776/2026, underscores a growing concern for out-of-network providers: an IDR determination is not the final step in the reimbursement process.
The dispute involved 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 30 calendar days. However, despite repeated reminders and demands, UnitedHealthcare did not pay. With support from CollectionPro Services LLC, a specialist in out-of-network reimbursement and IDR, the provider filed a petition in New York Supreme Court seeking enforcement of the award, statutory interest, the IDR entity fee, costs and disbursements, and other appropriate relief. This step illustrates the distinction between winning an IDR determination and actually collecting the awarded amount.
"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 beyond IDR filing to encompass the entire recovery lifecycle: 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 No Surprises Act. The company reports more than 10,000 out-of-network arbitrations filed and a 92% success rate. Its model includes advancing applicable arbitration costs and charging providers only after successful recovery.
The implications for out-of-network providers are significant. An IDR win can be hollow if the payer fails to pay, and pursuing payment may require additional legal action. Providers must be prepared to track awards, follow up on unpaid determinations, and escalate to enforcement when necessary. CollectionPro's involvement in this case highlights the value of specialized expertise in post-award collections, ensuring that providers maintain momentum throughout the reimbursement process instead of treating the arbitration decision as the finish line. As IDR volume grows, the ability to collect on awards will be as important as winning them.
