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Award enforcementProceeding

PHI Health, LLC v. Optimum Choice, Inc.

D. Md. · Updated

Summary

An air ambulance provider sued Optimum Choice, a UnitedHealthcare affiliate, to enforce an unpaid IDR award. On March 27, 2026, Judge Abelson denied the motion to dismiss, holding that the No Surprises Act itself authorizes judicial enforcement of an IDR payment obligation. The case remains pending in the District of Maryland.

Timeline of rulings

  1. D. Md.

    Motion to dismiss denied; the No Surprises Act authorizes judicial enforcement of an IDR determination when a plan fails to pay; court did not decide whether FAA § 9 separately applies.

    Read the ruling

Why it matters

It is one of the few decisions holding that providers can sue to enforce IDR awards, in tension with the Fifth and Second Circuits and with district courts in Illinois and Pennsylvania. Other courts have cited it on both sides of the district-court disagreement.

Related insights

Sources

  1. PHI Health, LLC v. Optimum Choice, Inc., Memorandum Opinion (D. Md. Mar. 27, 2026)
  2. GovInfo — PHI Health, LLC v. Optimum Choice, Inc., No. 1:25-cv-02320

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