Excision of a benign bone cyst or lesion in the foot with surgical filling of the resulting defect using bone graft material.
Verified May 8, 2026 · 4 sources ↓
- Medicare
- $396.80
- Work RVU
- 7.17
- Global, days
- 90
- Region
- Foot & ankle
Documentation requirements
What must appear in the operative or office note to support the claim.
Source · Editorial brief grounded in 4 cited references ↓
- Operative report must name the specific bone involved and confirm the lesion is intraosseous, not soft tissue.
- Specify graft type: autograft (with harvest site), allograft, or combination — each has distinct coding and documentation implications.
- Document the size and character of the lesion or cyst as confirmed by imaging or intraoperative findings.
- Preoperative imaging (X-ray, MRI, or CT) correlating with the operative site is required to support medical necessity.
- If autograft is harvested from a separate anatomic site, document that site explicitly in the operative note.
- Confirm the defect was actually filled with graft material — a curettage-only procedure without grafting does not support 28106.
Applicable modifiers
Modifiers commonly billed with this code.
Source · AMA CPT modifier descriptors · CMS NCCI Policy Manual
What this code covers
Source · Editorial summary grounded in 4 cited references ↓
28106 covers excision of a benign bony cyst or lesion from the foot, combined with grafting to fill the surgical void. The graft may be autograft, allograft, or a combination — the operative note must specify which type and the harvest site if autograft is used. This is not a soft-tissue excision; the lesion is intraosseous, and the procedure involves curettage or excision of abnormal bone followed by packing or structural grafting of the defect.
28106 carries a 90-day global period. Routine follow-up, dressing changes, and cast checks within that window are bundled. Bill modifier 24 for unrelated E/M visits and modifier 78 for an unplanned return to the OR for a related complication within the global. If the surgeon separately harvests autograft from a distant site, that harvest may be separately reportable — confirm against current NCCI edits before billing.
Local anesthesia injections are not separately billable when administered as part of the surgical approach. Fluoroscopy used intraoperatively to confirm graft placement is also bundled and cannot be separately reported per NCCI Chapter 4 policy.
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 (7.17) is the surgeon's own effort — the figure physician pay and productivity targets are built on. The total RVU (11.88) adds practice overhead and malpractice, and is what drives the Medicare payment below.
| Work RVU | 7.17 |
| Practice expense RVU | 4.11 |
| Malpractice RVU | 0.6 |
| Total RVU | 11.88 |
| Medicare national rate | $396.80 |
| 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 | $396.80 |
HOPD (APC 5114) Hospital outpatient department | $7,413.38 |
ASC (PI J8) Ambulatory surgical center (freestanding) | $4,682.29 |
Common denial reasons
The recurring reasons claims for CPT 28106 get rejected.
Source · Editorial brief grounded in CMS NCCI edits, AAOS coding appeals, and cited references ↓
- Operative note fails to confirm intraosseous lesion — soft-tissue excision codes do not crosswalk to 28106.
- Graft type not specified in the operative report, triggering medical necessity review or downcoding.
- Missing preoperative imaging to establish medical necessity for the excision and grafting.
- Local anesthesia or intraoperative fluoroscopy billed separately, creating an NCCI bundling conflict.
- Procedure billed during the global period of a prior related foot surgery without modifier 79 or 58 appended.
- Autograft harvest billed separately without documentation confirming a distinct donor site incision.
Frequently asked questions
Source · Generated from the editorial pipeline, verified against 4 cited references ↓
01What distinguishes 28106 from 28104 or 28108?
02Can autograft harvest be billed separately with 28106?
03Is intraoperative fluoroscopy separately billable with 28106?
04How does the 90-day global affect billing for cast or wound checks after this procedure?
05Can 28106 and a second foot procedure be billed on the same date?
06Does site of service affect reimbursement for 28106?
Sources & references
Editorial content was developed using the following public sources. Last verified May 8, 2026.
Mira Scribe
Mira's AI scribe captures the bone involved, lesion type and confirmed intraosseous character, graft material used (autograft with harvest site, allograft, or combination), and defect size from the surgeon's dictation. That prevents the most common 28106 denial: a note that describes curettage or soft-tissue work without explicitly confirming bone grafting of an intraosseous defect.
See how Mira captures CPT 28106 documentation