Soft tissue repair · Foot & ankle

20838

Surgical reattachment of a completely amputated foot, restoring bony, vascular, tendinous, and neural continuity.

Verified May 8, 2026 · 6 sources ↓

Medicare
$2,494.05
Total RVUs
74.67
Global, days
90
Region
Foot & ankle
Drawn from CMSEmednyAAPCNIH

Documentation requirements

What must appear in the operative or office note to support the claim.

Source · Editorial brief grounded in 6 cited references ↓

  • Mechanism of amputation and time of injury clearly stated
  • Warm and cold ischemia times documented in the operative note
  • All structures repaired listed explicitly: bone fixation method, vessel anastomoses (artery and vein by name), nerves, tendons
  • Surgeon's intraoperative assessment of tissue viability and perfusion at closure
  • Operative note must identify this as a complete amputation, not partial, to support 20838 over unlisted or lesser codes
  • Pre-op imaging or clinical findings confirming complete amputation level

Applicable modifiers

Modifiers commonly billed with this code.

Source · AMA CPT modifier descriptors · CMS NCCI Policy Manual

What this code covers

Source · Editorial summary grounded in 6 cited references ↓

CPT 20838 covers complete replantation of a foot following traumatic amputation. The procedure demands restoration of osseous fixation, arterial and venous anastomosis, nerve repair, and tendon reconstruction — typically performed by a microsurgical team over multiple hours. The 90-day global period encompasses all routine postoperative management from the day of surgery through day 90, including wound checks, dressing changes, and cast or splint management. Any unrelated procedure or E/M during that window requires modifier 79 or 24/25 respectively.

This is an inpatient-only procedure under CMS OPPS. CMS has designated 20838 with status indicator 'C,' meaning it cannot be paid in a hospital outpatient or ASC setting — the procedure must be performed and billed in an inpatient hospital context. Attempting to bill this in an HOPD or ASC setting will result in a non-covered denial; the HOPD and ASC payment amounts listed here reflect informational benchmarks, not payable claims in those settings.

Replantation cases carry substantial documentation burden. Operative notes must capture mechanism of injury, ischemia time, the sequence of repairs (bone fixation first vs. vascular shunting), all structures repaired, and the surgeon's assessment of viability at closure. Incomplete documentation is the primary audit trigger for this high-RVU code.

RVU & reimbursement

Component RVUs and Medicare national rate. Actual payment varies by GPCI locality.

Source · CMS Physician Fee Schedule, RVU26A · January 2026

Work RVU41.81
Practice expense RVU23.93
Malpractice RVU8.93
Total RVU74.67
Medicare national rate$2,494.05
Global period90 days

Payment by site of service

Medicare pays different rates by setting. HOPD typically pays substantially more than ASC for the same procedure.

Source · CMS OPPS Addendum B·ASC HCPCS payment rates·2026

SettingMedicare rate (national)
Office (PFS non-facility)
Procedure performed in physician's office
$2,494.05
HOPD (APC 5116)
Hospital outpatient department
$17,913.59
ASC (PI J8)
Ambulatory surgical center (freestanding)
$13,933.19

Common denial reasons

The recurring reasons claims for CPT 20838 get rejected.

Source · Editorial brief grounded in CMS NCCI edits, AAOS coding appeals, and cited references ↓

  • Billed in an HOPD or ASC setting — 20838 is inpatient-only (CMS status indicator C); site-of-service mismatch causes automatic non-covered denial
  • Operative note fails to specify ischemia time or structures repaired, flagging the claim for medical necessity review
  • ICD-10 diagnosis code does not confirm complete traumatic amputation of the foot at the correct level
  • Unbundling of component repairs (vessel anastomosis, nerve repair) that are integral to the replantation and not separately reportable
  • Global period violations — related E/M or procedure billed within 90 days without appropriate modifier 24, 25, 78, or 79

Frequently asked questions

Source · Generated from the editorial pipeline, verified against 6 cited references ↓

01Can 20838 be performed and billed in an ASC or hospital outpatient setting?
No. CMS designates 20838 as inpatient-only (status indicator C). Billing this in an HOPD or ASC will result in a non-covered denial. The procedure must be performed in an inpatient hospital setting.
02What is the global period for 20838, and what does it include?
20838 carries a 90-day global period. That covers the surgery date, the day-before visit, and all routine post-op care through day 90. Unrelated procedures need modifier 79; unrelated E/M visits need modifier 24.
03Can the microsurgeon separately bill for vessel anastomosis or nerve repair performed during foot replantation?
No. Vascular anastomosis, nerve repair, and tendon work are integral components of the replantation and are not separately reportable. Unbundling these will trigger NCCI edits.
04If a second surgeon assists, how is that reported?
The co-surgeon adds modifier 62 if two surgeons each perform distinct portions; modifier 80 (or AS for a PA/NP) applies for a standard assistant. Document each surgeon's distinct role in the operative note.
05What ICD-10 codes are typically required to support 20838?
Use a complete traumatic amputation code from the S98 category (traumatic amputation of ankle and foot) specifying the correct laterality and level. Partial amputation codes do not support 20838.
06If the replanted foot requires a return to the OR within the 90-day global for a related complication, how is that billed?
Use modifier 78 for an unplanned return to the OR for a complication related to the original replantation. Modifier 79 is for an unrelated procedure performed during the global period — do not invert these two.
07Does laterality need to be reported for 20838?
Yes. Append LT or RT to identify which foot was replanted. In the rare bilateral scenario, an ASC reports two claim lines with LT and RT; a physician practice reports modifier 50 on a single line per NCCI bilateral surgery rules.

Mira AI Scribe

Mira's AI scribe captures ischemia times, the sequence of repairs (osseous fixation, arterial and venous anastomosis, nerve coaptation, tendon reconstruction), and the surgeon's viability assessment at closure — the exact elements auditors check first on high-RVU replantation claims. Missing or vague operative detail is the leading reason these cases are pulled for post-payment review.

See how Mira captures CPT 20838 documentation

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