Excision or curettage of a bone cyst or benign tumor from a tarsal or metatarsal bone, excluding the talus and calcaneus, without bone grafting.

Verified May 8, 2026 · 6 sources ↓

Medicare: $540.76
Work RVU: 5.13
Global, days: 90
Region: Foot & ankle

Drawn from CMSAAPCPayerprice

Documentation requirements

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

Source · Editorial brief grounded in 6 cited references ↓

Specify the exact tarsal or metatarsal bone involved — 'foot lesion' alone is insufficient for audit defense.
Confirm the lesion type (bone cyst vs. benign tumor) with pre-op imaging or intraoperative findings documented in the operative note.
State that the talus and calcaneus were NOT the operative site; payers use this to distinguish 28104 from 28100/28102.
Document that no bone graft was harvested or implanted; if graft was used, 28106 applies instead.
Include laterality in both the operative note and the diagnosis coding to support LT/RT modifier use.
Pathology report or specimen disposition note when tissue is sent — supports medical necessity and lesion characterization.

Applicable modifiers

Modifiers commonly billed with this code.

Source · AMA CPT modifier descriptors · CMS NCCI Policy Manual

22 Increased complexity 51 Multiple procedures 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 6 cited references ↓

CPT 28104 covers surgical removal or curettage of a bone cyst or benign tumor located in the tarsal or metatarsal bones, specifically excluding the talus and calcaneus — those are captured under 28100/28102. No bone graft is used; if an iliac or other autograft is harvested and implanted, step up to 28106. The 90-day global period applies, covering all routine post-op care through day 90. Anything unrelated to the index procedure billed during that window requires modifier 24 or 25.

Site selection matters for payment. ASC and HOPD payments differ significantly — see the Site of Service comparison table. The code is most commonly billed by podiatry, though orthopedic surgery also reports it. Laterality modifiers (LT/RT) are expected when the operative foot is identifiable, which it always is.

Distinguish 28104 from 28288 (metatarsal head partial resection) — a common mix-up flagged in AAPC forums. 28288 removes bone as a structural correction; 28104 removes a discrete pathologic lesion. Using the wrong code invites NCCI scrutiny and payer downcoding.

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 (5.13) is the surgeon's own effort — the figure physician pay and productivity targets are built on. The total RVU (16.19) adds practice overhead and malpractice, and is what drives the Medicare payment below.

Work RVU	5.13
Practice expense RVU	10.42
Malpractice RVU	0.64
Total RVU	16.19
Medicare national rate	$540.76
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	$540.76
HOPD (APC 5113) Hospital outpatient department	$3,342.87
ASC (PI A2) Ambulatory surgical center (freestanding)	$1,644.87

Common denial reasons

The recurring reasons claims for CPT 28104 get rejected.

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

Wrong code selected — 28288 (metatarsal head resection) billed when a discrete bone cyst or tumor was excised, triggering a code mismatch denial.
Talus or calcaneus documented as the operative site, which falls under 28100/28102 and causes a descriptor mismatch.
Missing laterality modifier (LT or RT) — many payers require it for unilateral foot procedures and reject claims without it.
Bone graft documented in the operative note but 28104 billed instead of 28106, creating an unbundling flag.
Post-op visit billed without modifier 24 during the 90-day global period, resulting in automatic bundling denial.

Frequently asked questions

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

01What's the difference between 28104 and 28106?

28104 is excision or curettage without bone grafting. 28106 adds an iliac or other autograft. If you harvested and implanted graft material, 28106 is the correct code — billing 28104 in that scenario undercodes the procedure and misrepresents the operative work.

02Can I bill 28104 for a lesion on the talus or calcaneus?

No. Talus and calcaneus lesions are covered under 28100 (without graft) and 28102 (with graft). Using 28104 for those sites creates a descriptor mismatch and risks denial or audit flags.

03Do I need a laterality modifier on every 28104 claim?

Yes, for most payers. LT or RT is expected on unilateral foot procedures. Claims submitted without a laterality modifier are routinely rejected by commercial payers and Medicare Advantage plans. Add it at the time of coding, not after a denial.

04How does the 90-day global period affect post-op billing?

All routine post-op visits, wound checks, and stitch removals through day 90 are bundled into 28104. If you see the patient for an unrelated problem during that window, append modifier 24 to the E/M code. A return to the OR for a related complication uses modifier 78; unrelated surgery uses modifier 79.

05Can 28104 and 28288 be billed together on the same foot?

Only if the procedures are clearly distinct and performed on separate anatomical sites with separate indications. NCCI edits and payer logic flag this combination. You'll need modifier 59 (or XS for separate structure) with solid documentation supporting two distinct operative objectives — a bone cyst excision and a structural metatarsal head resection are different procedures, but auditors will scrutinize the operative note closely.

06Is pre-authorization typically required for 28104?

Authorization requirements vary by payer. Most commercial payers require prior auth for ASC-based elective procedures. Confirm with the specific plan before scheduling — HOPD and ASC site-of-service designations can also affect auth requirements independently.

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 excised (named tarsal or metatarsal), confirms exclusion of talus and calcaneus, notes absence of bone grafting, and flags laterality from dictation to auto-populate LT or RT. This prevents the most common 28104 denial: a vague operative note that fails to distinguish the procedure from 28100, 28102, or 28106.

See how Mira captures CPT 28104 documentation