Percutaneous tenotomy of multiple tendons within a single toe — used when both the extensor and flexor tendons (or more than one tendon) are released in the same toe during the same operative session.

Verified May 8, 2026 · 6 sources ↓

Medicare: $320.65
Work RVU: 4.17
Global, days: 90
Region: Foot & ankle

Drawn from TldsystemsAAPCCMSFindacode

Documentation requirements

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

Source · Editorial brief grounded in 6 cited references ↓

Specify each tendon released by name (e.g., flexor digitorum longus, extensor digitorum longus) — notes that say 'multiple tendons' without naming them are an audit risk.
Identify the specific toe(s) treated by number and laterality (right/left) to support toe modifier assignment.
Document the percutaneous technique explicitly; open tenotomy maps to different codes and a missing approach description causes downcoding.
Record the indication — diagnoses such as hammer toe contracture, mallet toe, or claw toe deformity — with functional impact that supports medical necessity.
Note anesthesia type used (local vs. general) and setting, as these affect facility billing and ASC vs. HOPD payment determination.

Applicable modifiers

Modifiers commonly billed with this code.

Source · AMA CPT modifier descriptors · CMS NCCI Policy Manual

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

What this code covers

Source · Editorial summary grounded in 6 cited references ↓

CPT 28011 covers a percutaneous tenotomy targeting multiple tendons in one toe. The surgeon uses a small needle or blade to make minimally invasive incisions, releasing or severing the contracted tendons without open exposure. The defining criterion is tendon count, not toe count: two or more tendons within the same toe trigger 28011, while a single-tendon release on any one toe uses 28010.

The 28010/28011 distinction is a frequent source of coding error. If the provider operates on multiple toes but releases only one tendon per toe, each toe is billed as 28010 (up to the applicable MUE limit per date of service), not 28011. Conversely, if both the extensor and flexor tendons are released within the same toe, 28011 applies once for that toe — not 28010 for the first tendon plus 28011 for the second. Misapplying this distinction is a common audit flag.

The 90-day global period covers all routine post-op care through day 90, including wound checks, dressing changes, and suture removal. Services unrelated to the tenotomy during that window require modifier 24 (E/M) or 79 (unrelated procedure). Toe modifiers (T-codes) are used by many payers to lateralize to the specific digit and are frequently required by commercial and Medicare Advantage plans.

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 (4.17) is the surgeon's own effort — the figure physician pay and productivity targets are built on. The total RVU (9.6) adds practice overhead and malpractice, and is what drives the Medicare payment below.

Work RVU	4.17
Practice expense RVU	5.02
Malpractice RVU	0.41
Total RVU	9.6
Medicare national rate	$320.65
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	$320.65
HOPD (APC 5112) Hospital outpatient department	$1,642.82
ASC (PI A2) Ambulatory surgical center (freestanding)	$872.87

Common denial reasons

The recurring reasons claims for CPT 28011 get rejected.

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

Billing 28011 when operative notes document only one tendon released — payers downcode to 28010 or deny the upcoded claim outright.
Missing or incorrect toe modifier when the payer requires digit-level specificity; claim edits reject without a valid T-code.
Unbundling 28010 and 28011 together for the same toe on the same date — NCCI considers this an invalid combination; only one code applies per toe per session.
Absence of a supporting diagnosis code that maps to tendon contracture or deformity — claims lacking a clear ICD-10 tie to the procedure are denied for medical necessity.
Global period conflicts when a post-op E/M is billed without modifier 24, triggering automatic denial within the 90-day window.

Frequently asked questions

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

01What is the difference between 28010 and 28011?

28010 applies when one tendon is released in a single toe. 28011 applies when two or more tendons are released within the same toe during the same session. The distinguishing factor is tendon count per toe, not the number of toes treated.

02If I release one tendon each in three different toes, do I bill 28011?

No. Three single-tendon releases across three toes bill as 28010 three times (with appropriate toe modifiers), not as 28011. 28011 only applies when multiple tendons are released within the same toe.

03Can 28010 and 28011 be billed together on the same date of service?

Yes, but only when they apply to different toes — for example, 28011 for one toe where both flexor and extensor were released, and 28010 for a separate toe where only one tendon was released. Billing both for the same toe on the same day is an NCCI bundling violation.

04Are toe modifiers required for 28011?

Medicare does not mandate T-codes for 28011, but many commercial payers and Medicare Advantage plans do require digit-level modifiers. Check individual payer contracts and LCDs. Omitting them where required is a clean-claim failure point.

05What is the global period for 28011 and what does it include?

28011 carries a 90-day global period. Routine post-op visits, wound care, dressing changes, and suture removal within those 90 days are bundled. Bill unrelated E/M with modifier 24; unrelated procedures with modifier 79.

06Can 28011 be billed bilaterally with modifier 50?

Yes, if multiple tendons are released in corresponding toes on both feet during the same session, modifier 50 applies. For ASC billing, report on two separate claim lines using LT and RT instead of a single line with modifier 50, per CMS NCCI policy.

Sources & references

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

Mira Scribe

Mira's AI scribe captures the operative note's tendon-level detail — recording each tendon by anatomic name, the percutaneous approach, the specific toe number, and laterality — directly from dictation. That granularity prevents the most common 28011 denial: a note that says 'tenotomy performed' without specifying which tendons were cut, which auditors and payers use to downcode to 28010 or reject medical necessity entirely.

See how Mira captures CPT 28011 documentation