Surgical removal of a subfascial (intramuscular) soft tissue tumor of the foot or toe measuring less than 1.5 cm.

Verified May 8, 2026 · 6 sources ↓

Medicare: $484.98
Work RVU: 5.31
Global, days: 90
Region: Foot & ankle

Drawn from CMSAAPCFindacodeSoapsuds

Documentation requirements

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

Source · Editorial brief grounded in 6 cited references ↓

Measured specimen size confirmed as less than 1.5 cm — document in the operative note and on the pathology requisition
Anatomic depth confirmed as subfascial (intramuscular/beneath the fascia), distinguishing from subcutaneous excision codes 28039/28043
Specific location of the tumor within the foot or toe, including laterality (right vs. left)
Pre-operative imaging or clinical workup supporting the diagnosis (ultrasound, MRI if deep tissue involvement was assessed)
Pathology report submitted with specimen to confirm tumor type and size
Operative note describing the approach, dissection planes, and confirmation that the mass was fully excised with clear margins

Applicable modifiers

Modifiers commonly billed with this code.

Source · AMA CPT modifier descriptors · CMS NCCI Policy Manual

22 Increased complexity 25 Significant separate E/M 24 Unrelated E/M during global 51 Multiple procedures LT Left side RT Right side 50 Bilateral procedure 59 Distinct service 78 Unplanned return — related 79 Unrelated during global 80 Assistant surgeon

What this code covers

Source · Editorial summary grounded in 6 cited references ↓

CPT 28045 covers excision of a subfascial soft tissue tumor — located beneath the fascia, within or between the muscles of the foot or toe — when the specimen measures less than 1.5 cm. This depth distinguishes it from subcutaneous lesion codes (28039, 28043): the tumor must be deep to the fascia, not simply below the skin. The excised specimen is sent for pathological analysis. Plantar fibromas within the plantar fascia are a common clinical scenario, but any subfascial mass of the foot or toe qualifying by size and depth falls under this code.

The 90-day global period bundles the operative visit, the day-before surgical visit, and all routine post-op management through day 90. Bill unrelated E/M visits during that window with modifier 24; a separate, significant E/M on the day of surgery requires modifier 25. Size is the primary code selector: if the tumor reaches 1.5 cm or larger, 28046 applies instead. Document the measured specimen size — not the incision length — in both the operative note and the pathology requisition.

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 (5.31) is the surgeon's own effort — the figure physician pay and productivity targets are built on. The total RVU (14.52) adds practice overhead and malpractice, and is what drives the Medicare payment below.

Work RVU	5.31
Practice expense RVU	8.67
Malpractice RVU	0.54
Total RVU	14.52
Medicare national rate	$484.98
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	$484.98
HOPD (APC 5073) Hospital outpatient department	$2,967.63
ASC (PI G2) Ambulatory surgical center (freestanding)	$1,248.36

Common denial reasons

The recurring reasons claims for CPT 28045 get rejected.

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

Size documentation missing or ambiguous — payers default to the wrong code when specimen measurement is absent from the operative note
Depth not established as subfascial — claims denied or downcoded to 28039/28043 when the note doesn't explicitly confirm the tumor was below the fascia
Laterality modifier absent — Medicare and many commercial payers require LT or RT on foot procedures; missing modifier triggers automated rejection
Mismatched ICD-10 diagnosis — submitting a superficial soft tissue diagnosis (e.g., epidermal cyst) with a subfascial excision code creates medical necessity conflicts
E/M billed same-day without modifier 25 — if a separate evaluation was performed before the surgical decision and billed concurrently, the E/M will be denied without modifier 25

Frequently asked questions

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

01What separates 28045 from 28043?

Depth. Code 28043 is for subcutaneous tumors of the foot or toe under 1.5 cm. Code 28045 is for the same size range but located subfascially — within or deep to the muscle fascia. The operative note must explicitly confirm depth to support 28045.

02When does size push you to 28046?

When the excised subfascial tumor measures 1.5 cm or larger, 28046 applies. Use the pathology-confirmed specimen size, not the clinical estimate or incision length, as the determining measurement.

03Is a plantar fibroma always coded to 28045?

Not automatically. A plantar fibroma within the plantar fascia is a common scenario for 28045, but the code applies to any subfascial soft tissue tumor under 1.5 cm. Confirm depth and size in each case before selecting the code.

04Can you bill a same-day E/M with 28045?

Yes, if the E/M was a significant and separately identifiable service beyond the surgical decision — but modifier 25 is required on the E/M. Without modifier 25, the E/M will be bundled into the surgical payment.

05Does the 90-day global cover post-op wound care?

Yes. Routine wound checks, dressing changes, and suture removal through day 90 are included in the global package. To bill separately for an unrelated condition during the global period, use modifier 24 on the E/M.

06Should pathology be billed separately?

Yes. The surgical code covers excision only. Submit the pathology analysis under the appropriate 88XXX code billed by the pathologist or laboratory — it is not bundled into 28045.

07Is modifier 50 appropriate for bilateral foot tumors excised in the same session?

Only if identical subfascial tumors are excised from both feet in the same encounter. More commonly, tumors are unilateral — use LT or RT. If two separate tumors are excised on the same foot, modifier 59 with modifier 51 may apply depending on NCCI edits; verify the specific pairing before submitting.

Sources & references

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

Mira Scribe

Mira's AI scribe captures the measured tumor size, anatomic depth relative to the fascia, and exact foot/toe location from the surgeon's dictation. It flags when the operative note lacks an explicit subfascial depth confirmation or a specimen measurement — the two documentation gaps most likely to trigger a downcode to 28039/28043 or a medical necessity denial.

See how Mira captures CPT 28045 documentation