Surgical · Foot & ankle

28005

Surgical incision through the foot bone cortex to drain or treat a bone lesion such as osteomyelitis or a bone abscess.

Verified May 8, 2026 · 5 sources ↓

Medicare
$534.75
Total RVUs
16.01
Global, days
90
Region
Foot & ankle
Drawn from CMSNIHAAPC

Documentation requirements

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

Source · Editorial brief grounded in 5 cited references ↓

  • Specify the exact bone(s) involved and anatomic location within the foot
  • Document the clinical indication by name — osteomyelitis, bone abscess, or other cortical lesion — supported by imaging or culture results when available
  • Describe the surgical approach: incision depth, cortical entry, extent of drainage or debridement performed
  • Record intraoperative findings including presence of purulence, necrotic bone, or abscess cavity
  • If billing same-day with other foot debridement codes, document the distinct nature of each service to support modifier 59 usage
  • Note culture specimens sent, wound irrigation performed, and closure or packing method used

Applicable modifiers

Modifiers commonly billed with this code.

Source · AMA CPT modifier descriptors · CMS NCCI Policy Manual

22 Increased complexity 50 Bilateral procedure 51 Multiple procedures 52 Reduced services 59 Distinct service 76 Repeat, same physician 78 Unplanned return — related 79 Unrelated during global LT Left side RT Right side

What this code covers

Source · Editorial summary grounded in 5 cited references ↓

CPT 28005 covers open incision into the cortex of a foot bone — the classic indication is osteomyelitis or a bone abscess requiring direct surgical drainage and debridement. The surgeon incises down to bone, opens the cortex, and addresses the infectious or lesional pathology. This is a distinctly deeper procedure than soft-tissue incision and drainage codes in the same family (28001–28003), and that distinction must be clear in the operative note.

The code carries a 90-day global period, so all routine follow-up, dressing changes, and wound checks through day 90 are included in the payment. Any staged or unplanned return to the OR within that window requires modifier 78 (related) or 79 (unrelated). Medicaid reimbursement for 28005 has been documented to vary widely across states — averaging meaningfully below Medicare in some programs — so know your payer mix before assuming Medicare-equivalent rates.

NCCI bundles 28005 with several overlapping foot debridement and bone codes, including 28120, 28122, 28062, and 28222. Appending modifier 59 (or an X-modifier) to unbundle is only appropriate when a separately identifiable and distinct service was performed — not simply because an incision was required to access a deeper structure. Audit exposure in diabetic foot cases is high given the frequency of multi-code billing in that population.

RVU & reimbursement

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

Source · CMS Physician Fee Schedule, RVU26A · January 2026

Work RVU9.2
Practice expense RVU5.85
Malpractice RVU0.96
Total RVU16.01
Medicare national rate$534.75
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
$534.75
HOPD (APC 5113)
Hospital outpatient department
$3,342.87
ASC (PI A2)
Ambulatory surgical center (freestanding)
$1,644.87

Common denial reasons

The recurring reasons claims for CPT 28005 get rejected.

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

  • NCCI bundling denial when billed same-day with 28120, 28122, 28062, or 28222 without a valid distinct-service modifier and supporting documentation
  • Medical necessity denial when the operative note fails to confirm cortical bone involvement — payers reject 28005 when documentation reflects only soft-tissue I&D
  • Global period denial for post-op services billed without modifier 24 or 25 when those services fall within the 90-day window
  • Modifier 59 or XS applied reflexively without documentation of a separately identifiable procedure, triggering payer audit or reversal
  • Laterality missing — claims without LT or RT modifier rejected by payers that require site identification for foot procedures

Frequently asked questions

Source · Generated from the editorial pipeline, verified against 5 cited references ↓

01What distinguishes 28005 from 28002 or 28003?
28002 covers subfascial space incision and 28003 covers muscle/tendon space — neither requires cortical bone entry. 28005 is specifically for incision through the bone cortex itself. The operative note must document cortical penetration to support 28005; soft-tissue drainage alone won't hold up on audit.
02Can 28005 be billed with 28122 or 28120 on the same day?
These pairs are NCCI-bundled. You can append modifier 59 only if the procedures were genuinely distinct — different anatomic sites or separately documented clinical indications. Billing 28005 alongside sequestrectomy or partial ostectomy codes just because both occurred in the same operative field is not sufficient justification.
03Is modifier 50 appropriate if both feet are treated?
Yes. If osteomyelitis or a bone abscess is treated bilaterally in the same operative session, bill 28005-50. Most payers reimburse bilateral procedures at 150% of the single-procedure allowable. Some payers prefer LT and RT on separate lines — check your payer's billing guidelines.
04What ICD-10 codes typically support 28005?
Osteomyelitis codes (M86.x series, including acute, subacute, and chronic, with foot/toe site specificity) are the primary drivers. Diabetic osteomyelitis with an E-code linking to foot complication (e.g., E11.69 with M86) is common. Bone abscess without osteomyelitis can be coded to M86.x or appropriate localized infection codes. Site specificity in the ICD-10 code should match the operative note.
05How does the 90-day global period affect billing for wound care after 28005?
Routine wound checks, dressing changes, and suture removal through day 90 are included — bill nothing separately for those. If a new problem unrelated to the original procedure arises and you see the patient in the office, bill with modifier 24. If a separate, significant procedure becomes necessary, use modifier 79 for an unrelated procedure or modifier 78 if the return to the OR is for a complication of the original surgery.
06Does Medicaid pay differently for 28005 than Medicare?
Yes, and the gap is notable. Published research documents that Medicaid reimbursement for 28005 averages below Medicare rates in many states — one analysis placed the average Medicaid rate roughly $95 less than Medicare. Rates vary from approximately 37% to over 300% of Medicare depending on the state, so verify your state's Medicaid fee schedule before estimating collections on diabetic foot cases.

Sources & references

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

  1. 01CMS Physician Fee Schedule 2026
  2. 02
    cms.gov
    https://www.cms.gov/medicare/coding-billing/national-correct-coding-initiative-ncci-edits/medicare-ncci-procedure-procedure-ptp-edits
  3. 03
    pmc.ncbi.nlm.nih.gov
    https://pmc.ncbi.nlm.nih.gov/articles/PMC12035350/
  4. 04
    aapc.com
    https://www.aapc.com/discuss/threads/28003-28005-with-28120-28122-28222-etc-bundling-debridement-diabetic-foot-podiatry-wound-care.183321/
  5. 05
    vsac.nlm.nih.gov
    https://vsac.nlm.nih.gov/context/cs/codesystem/CPT/version/2020/code/28005/info

Mira AI Scribe

Mira's AI scribe captures the bone(s) incised, depth of surgical approach through the cortex, intraoperative findings (abscess, osteomyelitis, necrotic bone), specimens sent to microbiology, and wound management at closure. That specificity prevents the most common denial for 28005: an operative note that documents soft-tissue dissection only, which payers use to downcode or reject the cortical incision claim entirely.

See how Mira captures CPT 28005 documentation

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