CollectionPro Services LLC, a specialist in out-of-network reimbursement and Independent Dispute Resolution (IDR), is highlighting a case that underscores a critical gap in the No Surprises Act arbitration process: winning an IDR determination does not guarantee payment. The case, Jason Weissler v. United Healthcare, Index No.: 652776/2026, involves 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. Despite the February 18, 2026, determination in the provider's favor, the award remained unpaid for months, forcing the matter into the New York State Supreme Court, New York County, under CPLR Article 75.
The dispute centered on CPT 19318, a code for breast reduction surgery. UnitedHealthcare offered $0, while the provider sought $72,000. The designated IDR entity selected the provider's full offer and declared the provider the prevailing party. The determination required payment within 30 calendar days, but repeated reminders and demands yielded no reimbursement. With CollectionPro's strategic guidance, the provider filed a petition to enforce the award, seeking the $72,000 plus statutory interest, the IDR entity fee, costs, and disbursements.
This case matters because it exposes a systemic flaw in the IDR process: even when providers win, they may face a second battle to collect. For business leaders in healthcare, particularly those managing out-of-network revenue, the implications are significant. The No Surprises Act was designed to provide a fair arbitration mechanism, but without enforcement, awards can become paper victories. Providers must now consider post-award strategies, including litigation, to secure payment. This adds legal costs and delays, straining cash flow and administrative resources.
David Nissanoff, spokesperson for CollectionPro, emphasized that providers should not assume their work is done after a favorable IDR determination. "The real objective is not just to win arbitration. It is to pursue the reimbursement the provider has been awarded," he said. "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, including open negotiation, IDR strategy, 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, with a model that advances arbitration costs and charges providers only after successful recovery. This end-to-end service is increasingly relevant as providers navigate a complex reimbursement environment.
The case also signals to payers that ignoring IDR awards may lead to court enforcement, potentially increasing their legal exposure and costs. For the broader healthcare industry, it highlights the need for robust compliance and payment processes. As IDR volume grows, so will the importance of ensuring that awards are honored. Providers and their advisors should evaluate their post-award protocols and consider partners like CollectionPro that offer enforcement support. Ultimately, the effectiveness of the No Surprises Act depends not just on fair arbitration but on reliable payment.
