Incision and drainage of an infected or inflamed bursa located in the foot.

Verified May 8, 2026 · 6 sources ↓

Medicare: $167.34
Total RVUs: 5.01
Global, days: 0
Region: Foot & ankle

Drawn from CMSAAPCNIHEmedny

Documentation requirements

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

Source · Editorial brief grounded in 6 cited references ↓

Confirm and document the bursa as superficial (above the deep fascia) to justify 28001 over 28002/28003
Specify the anatomic location of the bursa drained (e.g., retrocalcaneal, intermetatarsal, plantar)
Document clinical indication: signs of infection, acute bursitis, or failed conservative management
Record the drainage method, findings (purulent vs. serous fluid), volume, and any cultures obtained
If billing same-day with 28002 or 28003, document each distinct bursal space separately in the operative note

Applicable modifiers

Modifiers commonly billed with this code.

Source · AMA CPT modifier descriptors · CMS NCCI Policy Manual

LT Left side RT Right side 59 Distinct service XS Separate structure 51 Multiple procedures 25 Significant separate E/M 79 Unrelated during global 78 Unplanned return — related

What this code covers

Source · Editorial summary grounded in 6 cited references ↓

CPT 28001 describes surgical incision and drainage of a bursa of the foot — used when a foot bursa becomes infected, acutely inflamed, or otherwise requires operative drainage. This is a superficial bursal procedure distinct from the deeper subfascial drainage codes in the same family (28002 for single bursal space below fascia, 28003 for multiple areas below fascia). Selecting the right code from this cluster requires clear documentation of the depth of involvement and whether tendon sheaths are implicated.

The global period is 000, meaning routine post-op care on the day of surgery is bundled, but follow-up visits the next day and beyond bill separately. If a superficial I&D (28001) and a subfascial I&D (28002 or 28003) are performed on the same foot during the same session for distinct anatomic spaces, modifier 59 or XS supports separate billing — but document each space explicitly. Billing 28001 alongside 28002 without clear documentation of distinct locations is the primary NCCI edit exposure for this code.

Medicaid reimbursement for 28001 varies significantly by state — some states pay well above Medicare rates for this code, which the literature links to incentivizing treatment of diabetes-related complications. Verify your state fee schedule before estimating Medicaid revenue.

RVU & reimbursement

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

Source · CMS Physician Fee Schedule, RVU26A · January 2026

Work RVU	1.95
Practice expense RVU	2.88
Malpractice RVU	0.18
Total RVU	5.01
Medicare national rate	$167.34
Global period	0 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

Setting	Medicare rate (national)
Office (PFS non-facility) Procedure performed in physician's office	$167.34
HOPD (APC 5072) Hospital outpatient department	$1,687.37
ASC (PI P3) Ambulatory surgical center (freestanding)	$96.67

Common denial reasons

The recurring reasons claims for CPT 28001 get rejected.

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

Depth documentation missing — payer cannot distinguish superficial (28001) from subfascial (28002/28003) without explicit operative note language
Unbundling denial when 28001 and 28002 are billed together for the same foot without modifier 59 or XS and distinct anatomic space documentation
Medical necessity not established — lack of documentation showing failed conservative treatment or acute infectious presentation
ICD-10 diagnosis mismatch — bursitis codes (M71.x) not linked correctly to the foot-specific laterality or site

Frequently asked questions

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

01What's the difference between 28001, 28002, and 28003?

28001 is for drainage of a superficial bursa of the foot. 28002 moves below the deep fascia — single bursal space, with or without tendon sheath involvement. 28003 is the same subfascial approach but covers multiple areas. Depth and number of spaces determine the correct code; your operative note has to make that distinction explicit.

02Can I bill 28001 and 28002 together on the same day?

Yes, if you drained a superficial bursa and a separate subfascial space in the same foot during the same session. You need modifier 59 or XS on the lower-value code, and the operative note must document each distinct space. Without that, NCCI edits will bundle the claim.

03What global period applies to 28001?

28001 carries a 000 global period. The day-of-surgery follow-up is bundled; visits on subsequent days bill separately with no modifier required for unrelated E/M services.

04Which ICD-10 codes pair with 28001?

M71.371/M71.372 (other bursitis of foot, right/left), M71.379 (unspecified side), and infectious bursitis codes (M71.171/M71.172 for other infective bursitis of ankle and foot) are the primary supports. For diabetic patients, link the relevant diabetes complication code as a secondary diagnosis to strengthen medical necessity.

05Does Medicaid pay differently for 28001 than Medicare?

Yes, and significantly so. Published research shows state Medicaid reimbursement for 28001 ranges from well below to well above Medicare rates — some states pay substantially more, possibly to incentivize treatment of diabetes-related foot complications. Check your specific state Medicaid fee schedule; don't assume Medicare parity.

06Is 28001 appropriate for a non-infected inflamed bursa?

The code applies to incision and drainage of any bursa of the foot requiring operative intervention, not exclusively infected bursae. However, payers scrutinize medical necessity harder for non-infectious indications. Document prior conservative measures (aspiration, injection, orthotics, physical therapy) and clinical severity before proceeding to I&D.

Sources & references

Editorial content was developed using the following public sources. Last verified May 8, 2026.

Mira AI Scribe

Mira's AI scribe captures the bursa depth (superficial vs. subfascial), precise anatomic location on the foot, drainage findings including fluid character and estimated volume, and whether tendon sheaths were involved. This prevents the most common denial trigger for 28001 — vague depth documentation that auditors use to downcode or bundle the claim into an adjacent subfascial code.

See how Mira captures CPT 28001 documentation