A multi-location cosmetic surgery and dermatology group has taken UnitedHealthcare to the New York State Supreme Court, New York County, under CPLR Article 75 to enforce a $72,000 federal Independent Dispute Resolution (IDR) award that the payer failed to pay, according to CollectionPro Services LLC. The case, Jason Weissler v. United Healthcare (Index No.: 652776/2026), underscores a systemic flaw in the No Surprises Act arbitration process: winning a determination does not guarantee payment.
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 payment within the applicable 30-calendar-day period, but the award remained unpaid for months despite repeated reminders and demands.
With strategic guidance from CollectionPro, the provider filed a petition seeking enforcement and payment of the $72,000 award, along with statutory interest, the IDR entity fee, associated costs and disbursements, and any other appropriate relief. "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 spans the recovery lifecycle, including open negotiation, IDR strategy, evidence development, IDR determination, 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, while its model includes advancing applicable arbitration costs and charging providers only following successful recovery. For more information, visit CollectionPro.
For HR vendors and solution providers, this case signals a growing demand for tools and services that address the entire revenue cycle, not just the arbitration filing. Payers increasingly delay or refuse payment even after an IDR entity rules in a provider's favor. That gap creates opportunities for vendors offering post-award tracking, legal enforcement support, and integrated claims recovery platforms. It also increases pressure on HR and benefits technology companies to ensure their networks and claims systems can handle out-of-network disputes end-to-end.
The case highlights that providers must be prepared to pursue legal enforcement to secure reimbursement. As more providers face unpaid awards, the market for comprehensive dispute resolution services is likely to expand, and vendors that can demonstrate measurable recovery outcomes will be well positioned.
