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using 99080 more than 12 diagnosis codes to report submit 2 claims (split)

I am looking for advice for when a provider wants to submit more than the 12 diagnosis codes from an annual wellness exam for the sole purpose of Risk Adjustment. Let’s say the provider has 15 in total to submit.
Wouldn’t the provider split the claim? Submitting the first claim with the CPE 99397, then CPT code such as 99080 for the 11 remaining codes (B-L) of course 99080 only allows the 4 codes on each charge line (total of 3 99080 lines on the first claim), then the second claim only has 99080 with the additional 3 diagnosis codes?
This is a new process to me that providers are wanting to take on. So I’m looking for advice, since there seems to be very little information out there on this subject.
Thank you

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