Twice recently I have had procedures where the physician performed a lot more than 20 incisions (first time was over 100, second was over 50). There is no limit on the code it just says "more than 20 incisions" but these seemed like unusual circumstances and I billed with a modifier 22 but insurance denied paying anything additional. The only information I can find for CPT 37766 just explains criteria for it to be covered but nothing about extreme circumstances.