Excision of a bone cyst or benign tumor from the talus or calcaneus with allograft implantation to reconstruct the defect site.

Verified May 8, 2026 · 5 sources ↓

Medicare: $361.73
Total RVUs: 10.83
Global, days: 90
Region: Foot & ankle

Drawn from CMSStaticAofas

Documentation requirements

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

Source · Editorial brief grounded in 5 cited references ↓

Confirm the specific bone involved — talus or calcaneus — named explicitly in the operative note
Document lesion type (bone cyst vs. benign tumor) with pre-operative imaging correlation
Specify allograft source and confirm allograft — not autograft — was used for cavity reconstruction
Record lesion size and depth to support medical necessity review
Document complete excision technique and graft fixation method used intraoperatively
Include pathology submission or intraoperative frozen section findings when applicable

Applicable modifiers

Modifiers commonly billed with this code.

Source · AMA CPT modifier descriptors · CMS NCCI Policy Manual

22 Increased complexity 52 Reduced services 58 Staged or related 59 Distinct service 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 28103 covers open excision of a bone cyst or benign tumor located in the talus or calcaneus, followed by harvesting and implantation of an allograft to fill and stabilize the resulting bony defect. The allograft component is what distinguishes 28103 from 28100 (no graft) and 28102 (autograft). If your surgeon packed the cavity with autograft rather than allograft, 28102 is the correct code — payer auditors and NCCI edits will catch the mismatch.

The 90-day global period means all routine follow-up, dressing changes, and post-op visits through day 90 are bundled. Any visit for an unrelated condition during that window requires modifier 24 on the E/M. If the patient returns for a complication requiring a return to the OR for a related procedure, bill modifier 78. An unrelated surgical procedure in the global window gets modifier 79.

Cigna's coverage policy lists 28103 as an investigational code when used for osteochondral autograft or allograft transplantation to treat articular cartilage defects at sites other than the femoral condyle or patella — this is a distinct clinical scenario from simple cyst excision-and-graft. Confirm the documented indication matches your payer's covered diagnosis list before submitting.

RVU & reimbursement

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

Source · CMS Physician Fee Schedule, RVU26A · January 2026

Work RVU	6.5
Practice expense RVU	3.78
Malpractice RVU	0.55
Total RVU	10.83
Medicare national rate	$361.73
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	$361.73
HOPD (APC 5114) Hospital outpatient department	$7,413.38
ASC (PI J8) Ambulatory surgical center (freestanding)	$4,961.12

Common denial reasons

The recurring reasons claims for CPT 28103 get rejected.

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

Graft type mismatch — autograft used but 28103 (allograft) billed instead of 28102
Payer treats the procedure as investigational when billed for osteochondral cartilage defects rather than bone cyst or benign tumor
Missing or vague operative note — 'standard approach' language without named bone, lesion type, or graft details
Diagnosis code does not support the procedure — ICD-10 must specify a benign neoplasm or cyst of the talus or calcaneus
Global period billing conflict — E/M visit during the 90-day window submitted without modifier 24 for an unrelated condition

Frequently asked questions

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

01What is the difference between 28100, 28102, and 28103?

28100 is excision without a graft. 28102 uses autograft (tissue from the same patient). 28103 requires allograft (donor tissue). The operative note must specify which graft type was implanted — the codes are not interchangeable and payers audit graft type closely.

02Does the 90-day global period apply to 28103?

Yes. The global period is 90 days. Routine post-op visits, dressing changes, and suture removal within that window are bundled. Bill modifier 24 on any E/M for an unrelated condition, modifier 78 for a related unplanned return to the OR, and modifier 79 for an unrelated surgical procedure.

03Will Cigna cover 28103 for osteochondral lesion repair?

Not reliably. Cigna's coverage policy lists 28103 as a code associated with osteochondral transplantation for cartilage defects at non-femoral/patellar sites — and classifies that indication as investigational. Coverage for straightforward benign cyst excision with allograft may differ. Verify the specific indication against the active Cigna policy before submitting.

04Can 28103 be billed with imaging or bone grafting supply codes on the same day?

Allograft bone is typically billed separately using applicable HCPCS supply codes, but confirm your payer's policy — some bundle the graft material cost into the surgical code. Imaging obtained on the same day is generally separately billable with modifier 59 if it was independently medically necessary and not just intraoperative localization.

05Is 28103 payable in an ASC setting?

Yes. CMS assigns this procedure an ASC payment rate. See the Site of Service comparison on this page for the current HOPD and ASC payment figures under the 2026 CMS Physician Fee Schedule.

06What ICD-10 codes support 28103?

The diagnosis should reflect a benign bone neoplasm or cyst of the talus or calcaneus — for example, codes from the M85 (bone cyst) or D16 (benign neoplasm of bone) categories. An osteochondral lesion of the talus coded to M93.27x may trigger investigational review depending on payer, so confirm coverage policy alignment before submitting.

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 specific bone (talus vs. calcaneus), lesion characterization (cyst or benign tumor), graft type (allograft confirmed), graft fixation technique, and lesion dimensions directly from surgeon dictation. That prevents the most common 28103 denial: a graft-type mismatch where autograft was used but the allograft code was billed — or vice versa.

See how Mira captures CPT 28103 documentation