A recent dispute involving a multi-location cosmetic surgery and dermatology group is drawing attention to a critical gap in the out-of-network reimbursement process: even a decisive victory in federal Independent Dispute Resolution (IDR) may not result in payment. The case, Jason Weissler v. United Healthcare, Index No.: 652776/2026, was filed in the New York Supreme Court after UnitedHealthcare allegedly failed to pay a $72,000 IDR award.
The conflict centered on CPT 19318, a billing code for breast reduction surgery. According to CollectionPro Services LLC, a specialist in out-of-network reimbursement, 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 offer and declared the provider the prevailing party. Under the No Surprises Act, the IDR determination required payment within 30 calendar days. However, the award remained unpaid for months despite repeated reminders and demands, according to CollectionPro.
The case matters because it illustrates a growing concern for out-of-network providers: an IDR win is only as valuable as the payment it produces. When a payer refuses to pay, the provider must pursue additional legal remedies to enforce the award. With CollectionPro's strategic guidance, the matter proceeded to the New York State Supreme Court under CPLR Article 75. The petition sought enforcement and payment of the $72,000 award, along with statutory interest, the IDR entity fee, associated costs and disbursements, and other appropriate relief. The move underscores that providers may need to escalate beyond the arbitration process to secure the reimbursement they are owed.
"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, 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, advancing applicable arbitration costs and charging providers only after successful recovery. For providers navigating the No Surprises Act, the case signals that winning IDR is only one step; collecting the award may require persistent follow-through and legal action. More information is available at CollectionPro.
