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Award enforcementOn appeal

Agag v. Cigna Health and Life Insurance Co.

D. Conn. → 2d Cir. · Updated

Summary

A plastic surgeon sought confirmation of unpaid IDR awards against Cigna. On April 15, 2026, Judge Underhill dismissed the NSA damages and FAA § 9 claims but, without finding an implied right of action, held that confirmation is not 'judicial review' barred by the NSA and confirmed the awards; judgment for $142,567.99 entered April 16. Cigna appealed to the Second Circuit (No. 26-1241).

Timeline of rulings

  1. D. Conn.

    Cigna's notice of appeal to the Second Circuit filed.

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  2. D. Conn.

    Judgment entered confirming the IDR awards for $142,567.99.

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  3. D. Conn.

    Motion to dismiss granted as to FAA § 9 confirmation and NSA damages, otherwise denied; cross-motion to confirm IDR awards granted and judgment of $142,567.99 directed.

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Why it matters

Agag offered providers a confirmation route that avoids the private-right-of-action question. Its appeal is pending in the Second Circuit, which held in September 2026 that the NSA creates no private right of action to enforce awards but expressly left open whether suits to confirm awards are barred.

Related insights

Sources

  1. Agag v. Cigna, Order on Motion to Dismiss and Cross-Motion to Confirm (D. Conn. Apr. 15, 2026)
  2. Agag v. Cigna, Judgment (D. Conn. Apr. 16, 2026)
  3. O'Neill Institute tracker — Agag v. Cigna (D. Conn.)
  4. O'Neill Institute tracker — Agag v. Cigna (2d Cir. No. 26-1241)

General information only, not legal advice. Verdict Consulting Group is not a law firm.