Without seeing the actual documentation it is hard to answer correctly. But read the CPT Guidelines for Repair (Closure) - in the 2010 CPT Professional Editition, these are on page 64.
Complex repair includes the repair of wounds requiring more than layered closure, viz., scar revision, debridement (eg. traumatic lacerations or avulsions), extensive undermining ... (emphasis added by FTB)
Hope that helps.
F Tessa Bartels, CPC, CEMC
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