Modifier 79

I would say add the 79 to both. You are basically telling the payer that 20610 RT & LT are unrelated procedures to the previous toe fracture. Instead of saying just the LT or the RT is unrelated.

Our common sense would say that the payer should see different diagnosis codes (for the toe fracture encounter & the knee injection encounter) & allow for payment on the 20610 codes but it's never that easy with payers :-)

Side note, follow up with the payer to see if the bilateral ICD10 code being used on the procedure with the RT or LT modifier rejects.

For example,
For payers that prefer we itemize out the CPT 20610 on two lines, our orthopedic office will use the unilateral ICD10 code to match with the unilateral procedure.
For payers that prefer bilateral billing, our orthopedic office will use the bilateral ICD10 code to match with the bilateral procedure (20610-50).
Other coders will probably have different opinions on this (I've seen it in these forums since ICD10 implementation) but this is how we bill these scenarios & we don't see specific reimbursement issues (for this at least!).

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Modifier 79