CollectionPro Services LLC, a specialist in out-of-network reimbursement and Independent Dispute Resolution (IDR), is drawing attention to a recent case that illustrates a critical gap in the No Surprises Act arbitration process: winning an IDR determination does not guarantee payment. The case, Notice of Petition Jason Weissler v. United Healthcare Index No.: 652776/2026, involved a multi-location cosmetic surgery and dermatology group that prevailed in Federal IDR with a $72,000 award after UnitedHealthcare submitted an offer of $0. Yet the award remained unpaid, 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, a breast reduction procedure. UnitedHealthcare offered $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 IDR determination required payment within 30 calendar days. However, months passed without payment despite repeated reminders and demands. With CollectionPro's strategic guidance and active support, the matter proceeded to court to enforce the award, seeking the $72,000 plus statutory interest, the IDR entity fee, costs, and disbursements.
The case highlights a growing concern for out-of-network providers: a favorable IDR determination is not the end of the reimbursement journey. "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 recovery 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 more than 10,000 out-of-network arbitrations filed and a 92% success rate, and it advances applicable arbitration costs, charging providers only after successful recovery.
For providers, the implications are significant. An IDR win can be hollow if the payer refuses to pay, leaving providers with legal fees and delayed revenue. CollectionPro's involvement in this case demonstrates that post-award enforcement is a necessary component of a comprehensive reimbursement strategy. Providers can learn more about CollectionPro's services at https://www.collectionpro.com and about the No Surprises Act IDR process at https://www.cms.gov/nosurprises.
As unpaid awards become more common, the distinction between winning an arbitration and actually collecting the award is crucial. CollectionPro's support in this case serves as a reminder that providers must be prepared to pursue enforcement when payers fail to comply with IDR determinations.
