My take on this...
What you "bill" is only related to what you receive in payment if you charge less than your "contracted" fee. How often do you get what you bill? You charge the same to each insurance company knowing you will get different reimbursement. I don't think your billing schedule is in question. The problem may arise if two docs colluded on setting their "contracted fee". I think you can use identical fee schedules. If you each bill $100 for a 9921X, your contracted rate may be 92.71 and his 93.54. No conflict.
