Subcutaneous tenotomy of a single toe tendon, performed percutaneously without open dissection.

Verified May 8, 2026 · 7 sources ↓

Medicare: $235.48
Work RVU: 2.9
Global, days: 90
Region: Foot & ankle

Drawn from CMSAAPCTldsystemsPodiatrymEmedny

Documentation requirements

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

Source · Editorial brief grounded in 7 cited references ↓

Identify the specific toe(s) treated and which tendon(s) were released (flexor vs. extensor, EDL vs. FDL).
Document the approach as percutaneous/subcutaneous — not just 'tenotomy performed' — to distinguish from open codes 28230/28232.
Record the joint level addressed (DIP vs. PIP) when reporting 28010 alongside 28285 to support separate incision/site rationale.
When multiple toes are treated, document each digit individually with clinical justification for each release.
Note any staged procedure context and rationale if a second tenotomy on the contralateral foot occurs within the 90-day global.

Applicable modifiers

Modifiers commonly billed with this code.

Source · AMA CPT modifier descriptors · CMS NCCI Policy Manual

22 Increased complexity 51 Multiple procedures 58 Staged or related 59 Distinct service 79 Unrelated during global LT Left side RT Right side

What this code covers

Source · Editorial summary grounded in 7 cited references ↓

CPT 28010 covers a percutaneous (subcutaneous) tenotomy of a single tendon in one toe — typically the flexor digitorum longus or extensor digitorum longus — using a blade or needle to release the tendon through a small stab incision rather than open exposure. It carries a 90-day global period, meaning all routine post-op care through day 90 is bundled.

28010 is billed per toe, per tendon. If the surgeon releases one tendon in two different toes on the same date, bill 28010 twice with the appropriate T-modifier on each line (e.g., 28010-T6, 28010-T7). The MUE allows up to four units per date of service. If two tendons in the same toe are released percutaneously, step up to 28011 — not multiple units of 28010. Modifier 51 is generally not needed when T-modifiers already distinguish the separate digits.

When 28010 is performed in conjunction with hammertoe correction (28285), bundling scrutiny applies. Open flexor tenotomy (28232) carries its own separate-procedure designation, but percutaneous flexor tenotomy via a plantar stab incision or at a different joint level (DIP vs. PIP) may support separate reporting of 28010 alongside 28285 with modifier 59 — though payer push-back is common and should be anticipated. Extensor tenotomy is considered inclusive to 28285 per AAOS Global Service Data and should not be billed separately.

RVU & reimbursement

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

Source · CMS Physician Fee Schedule, RVU26A · January 2026

Work RVU vs. total RVU

The work RVU (2.9) is the surgeon's own effort — the figure physician pay and productivity targets are built on. The total RVU (7.05) adds practice overhead and malpractice, and is what drives the Medicare payment below.

Work RVU	2.9
Practice expense RVU	3.89
Malpractice RVU	0.26
Total RVU	7.05
Medicare national rate	$235.48
Global period	90 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	$235.48
HOPD (APC 5112) Hospital outpatient department	$1,642.82
ASC (PI P3) Ambulatory surgical center (freestanding)	$130.91

Common denial reasons

The recurring reasons claims for CPT 28010 get rejected.

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

Billing multiple units of 28010 without T-modifiers — payers deny duplicate procedure codes that lack digit-specific identifiers.
Bundling denial when 28010 is billed same-day with 28285 on the same toe without a supporting separate-site or separate-incision rationale and modifier 59.
Unbundling error: billing 28010 when 28011 is correct because two tendons in the same toe were released percutaneously.
Missing or vague operative note — documentation that doesn't name the tendon or confirm percutaneous technique triggers downcoding or denial.

Frequently asked questions

Source · Generated from the editorial pipeline, verified against 7 cited references ↓

01Can I bill 28010 twice if I release the same tendon in two different toes on the same day?

Yes. Bill 28010 on separate lines with the appropriate T-modifier for each digit (e.g., 28010-T6 and 28010-T7). The MUE allows up to four units per date of service. Modifier 51 is generally unnecessary when T-modifiers already distinguish the procedures.

02When should I use 28011 instead of 28010?

Use 28011 when two or more tendons in the same toe are released percutaneously — for example, both the flexor and extensor on the third digit. 28010 is strictly one tendon per toe; 28011 covers multiple tendons in a single toe.

03Is 28010 bundled into hammertoe correction (28285)?

Extensor tenotomy is considered inclusive to 28285. Percutaneous flexor tenotomy (28010) may be separately reportable if performed through a distinct plantar incision or at a different joint level (DIP vs. PIP), but append modifier 59 and expect payer push-back — some payers bundle both regardless.

04A surgeon released a toe tendon, then five days later released the contralateral toe tendon. How do I bill the second procedure?

The second procedure falls within the 90-day global of the first. Append modifier 79 (unrelated procedure) if the second toe is clinically unrelated, or modifier 78 if it's a complication or directly related to the first. Document the clinical rationale for the staged approach.

05Do I need modifier 50 for bilateral tenotomy?

No. The bilateral surgery indicator for 28010 is 0, meaning the 150% bilateral adjustment does not apply. Bill each toe on a separate line with T-modifiers instead of using modifier 50.

06What's the difference between 28010 and 28232 in terms of coding?

28010 is percutaneous (subcutaneous stab incision); 28232 is open flexor tenotomy requiring direct tendon exposure. The operative note must clearly document the approach — a percutaneous technique billed as 28232 is an upcoding risk, and an open procedure billed as 28010 is a downcoding loss.

Sources & references

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

Mira Scribe

Mira's AI scribe captures the tendon name (flexor vs. extensor), the specific digit, the joint level (DIP vs. PIP), and the percutaneous technique from dictation — and flags when the note would support 28011 instead of 28010. That prevents the most common audit trigger: an operative note that says 'tenotomy of toe' without specifying whether one or multiple tendons were released, or whether the approach was open or subcutaneous.

See how Mira captures CPT 28010 documentation