Would like everyone’s opinion with this situation. I have a series of CPT codes reported on the same encounter, same patient, ect. There are duplicate service codes reported for one service. The MUE is 2, and there are no NCCI edits when coded with the other services on the same claim.
A colleague of mine is adamant that we should report that code, on two different lines, with a modifier XS on the second line.
My argument is, that CPT code, has a MUE of 2, is not subject to the multiple payment policy indicator of 2, nor the payment policy indicator of 3, and has no bundled edits, therefore, we should be reporting that code, one one line, with a total unit of 2 in lieu of reporting the XS modifier, and splitting out the code.

Any takers on this? I am fully aware of Medicare’s guidelines with regards to the 59 modifier, but I do not see anything that can back up my analysis of this stating we should not be reporting this way, because it is improper coding, and can trigger an audit.