Radical resection of a soft tissue tumor of the foot or toe, with the tumor and its excised margins measuring less than 3 cm in greatest dimension.

Verified May 8, 2026 · 6 sources ↓

Medicare: $661.67
Work RVU: 12.07
Global, days: 90
Region: Foot & ankle

Drawn from CMSFindacodeAAPCMdclarityGenhealth

Documentation requirements

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

Source · Editorial brief grounded in 6 cited references ↓

Operative note must specify tumor location — name the exact anatomic structure (e.g., plantar fascia, dorsal forefoot, specific toe) and laterality.
Document the clinical or radiologic basis for suspecting malignancy; radical resection requires oncologic intent, not just large size.
Record the measured specimen size including margins, confirming the combined diameter is less than 3 cm.
Describe the tissue planes dissected and the extent of surrounding tissue removed to distinguish radical from simple excision technique.
Include the final or preliminary pathology report in the chart; payers may audit for histologic correlation with the malignancy-suspected indication.
Note any imaging (MRI, ultrasound) used for pre-op planning or intraoperative guidance, and whether guidance was separately billed.

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 59 Distinct service 76 Repeat, same physician 78 Unplanned return — related 79 Unrelated during global LT Left side RT Right side XS Separate structure

What this code covers

Source · Editorial summary grounded in 6 cited references ↓

CPT 28046 covers radical resection of a soft tissue tumor — typically a suspected or confirmed malignancy such as a sarcoma — located in the foot or toe, where the combined specimen (tumor plus margins) measures less than 3 cm. Unlike a simple excision, radical resection requires removal of surrounding tissue beyond the tumor capsule to achieve clear oncologic margins. The procedure is performed under the assumption of malignant behavior; a benign lesion removed with simple excision technique belongs under a different code family.

The 90-day global period means all routine follow-up care — wound checks, dressing changes, suture removal, and related office visits — is bundled through day 90. Pathology is separately reportable; the surgical code does not include specimen analysis. If imaging guidance is used during the resection, check whether it is integral to the approach before billing a separate radiology code.

Site of service matters significantly here. The gap between HOPD and ASC reimbursement is substantial — see the Site of Service comparison table for current 2026 figures. Most of this volume flows through podiatry, though orthopedic oncology and general orthopedic surgeons also perform the procedure. When the same physician later excises a recurrence or performs a staged wider resection within the global period, modifier 78 (unplanned return, related procedure) is required.

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 (12.07) is the surgeon's own effort — the figure physician pay and productivity targets are built on. The total RVU (19.81) adds practice overhead and malpractice, and is what drives the Medicare payment below.

Work RVU	12.07
Practice expense RVU	6.28
Malpractice RVU	1.46
Total RVU	19.81
Medicare national rate	$661.67
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	$661.67
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 28046 get rejected.

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

Malignancy not supported by documentation — payers deny when the operative note or ICD-10 diagnosis reflects a clearly benign lesion rather than a suspected or confirmed malignancy.
Size threshold mismatch — billing 28046 when the specimen or margin measurement meets the ≥3 cm threshold that maps to the higher-complexity sibling code.
Laterality not specified — missing LT or RT modifier triggers claim edits and delays, particularly for Medicare.
Bundling conflict with same-day procedures performed on the same foot without modifier 59 or an XS modifier to establish distinct service.
Global period violation — follow-up E/M visits billed without modifier 24 during the 90-day postoperative window.

Frequently asked questions

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

01What separates 28046 from a simple excision of a foot mass?

28046 requires radical resection — removal of the tumor plus a cuff of surrounding normal tissue — performed with oncologic intent for a suspected or confirmed malignancy. Simple excision of a benign soft tissue mass in the foot routes to a different code family. The operative approach, not just the size, drives the code selection.

02Which ICD-10 diagnoses support 28046?

Confirmed soft tissue sarcomas of the foot and toe (C49.2x), malignant neoplasm codes specific to foot soft tissue, and high-suspicion lesions documented as 'suspected malignant' in the clinical record. Coding a benign diagnosis like plantar fibroma (M72.2) against 28046 will draw payer scrutiny because the code requires oncologic resection intent.

03Do I need laterality modifiers for 28046?

Yes. Append LT or RT on every claim. Per CMS NCCI 2026 policy, procedures on toes should also use toe-specific modifiers (TA, T1–T9) when the same procedure is billed on multiple toes. MUE values for many toe procedures are set at one unit precisely because these modifiers handle multi-toe scenarios.

04Can I separately bill pathology when I submit 28046?

Yes. The surgical CPT does not bundle pathologic examination of the specimen. Report the appropriate surgical pathology code separately. Make sure the path report is in the chart before the claim closes — auditors correlate histology with the malignancy-intent diagnosis.

05If I need to return to the OR during the 90-day global to address a wound complication, what modifier applies?

Modifier 78 covers an unplanned return to the OR for a complication directly related to the original resection — for example, hematoma evacuation or wound dehiscence repair. Modifier 79 applies only if the return procedure is unrelated to the original surgery. Do not use 79 for complications of 28046.

06Is 28046 typically performed in an ASC or HOPD, and does it affect reimbursement?

Both settings are used, but the reimbursement gap is material — see the Site of Service comparison table for 2026 HOPD versus ASC payment figures. Podiatry accounts for the majority of 28046 volume per CMS PUF data. Facility choice should factor in case complexity, anesthesia needs, and payer contract terms.

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 anatomic site and laterality of the tumor, the surgeon's stated oncologic intent (radical vs. simple excision), measured specimen dimensions including margins, and the tissue planes dissected. This prevents the two most common denial triggers for 28046: a vague operative note that doesn't establish malignancy suspicion, and a missing or incorrect size measurement that misroutes the claim to the wrong resection code.

See how Mira captures CPT 28046 documentation