Medicare is bundling excision of benign lesion .5cm or less with intermediate closure.

Based on the CPT manual instructions that intermediate and complex closures should be reported separately, my physician wants to add a 59 modifier to the closure.

It is my understanding that Medicare considers simple, intermediate and complex closure inclusive when the removal of the benign lesion is .5cm or less.
The codes are NCCI edits and can be overridden by adding modifier 59 to the repair. Since the repair is not a separate encounter, separate structure, separate practitioner or unusual non-overlapping service, would modifier 59 really apply?

CPT’s 11440
CPT’s 12011, 12051, 13151

Please advise.

Thanks,
Camille Waterhouse, CPC