there is an AAOS june 2004 article you can look up. AAOS states you can only bill hardware removal once, no matter how many plates, screws, wires, incisions.
I believe they base it off the original surgery code, if you billed orif of tri mal fx, then all hardware removed for that fx is included in 20680, even if there were 2 incisions (med and lat).
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