Bundling

“Medicare sent me a letter about 6 months ago saying I bill CPT 11721 too often compared to CPT 11720 and CPT 11719. However, they consistently deny the combination of CPT 11719 and CPT 11720-59. Not just bundled, but deny both codes, altogether. That then leaves me an outlier with a bunch of CPT 11721 counted and all of the CPT 11719 and CPT 11720 denials left out of the calculations. Appeals are denied (and a waste of time and resources for $11). Their CCI indicator is 1, meaning they can be billed together with 59 or X- modifier on the column 2 code (CPT 11720). Is it fraudulent billing to code only CPT 11720 even though I am debriding 1 to 4 nails and trimming the rest? It also pays more with just CPT 11720 since it is otherwise secondary to a less-than-$11 CPT 11719 code. I hate to turn away these patients who have a true need. Recommendations?”