Advanced Vascular Associates v. Horizon Blue Cross Blue Shield of New Jersey
E.D. Pa. · Updated
Summary
A provider asked the Eastern District of Pennsylvania to confirm an unpaid IDR award or let it sue under the No Surprises Act. On April 7, 2026, Judge Wolson granted Horizon judgment on the pleadings and closed the case: Congress authorized neither FAA confirmation of IDR awards nor a private cause of action to compel payment.
Timeline of rulings
- E.D. Pa.
Horizon's motion for judgment on the pleadings granted and provider's cross-motion to confirm denied; no FAA confirmation and no express or implied private right of action to enforce IDR awards.
Read the ruling
Why it matters
It is an early decision in the Third Circuit rejecting both routes providers use to collect unpaid awards, FAA § 9 confirmation and an implied NSA right of action. Other courts, including in E.D. Pa. and N.D. Ill., have since cited it.
Related insights
Sources
General information only, not legal advice. Verdict Consulting Group is not a law firm.