Surgical removal of a bone cyst or benign tumor from the phalanges (toe bones) of the foot.

Verified May 8, 2026 · 5 sources ↓

Medicare: $431.21
Work RVU: 4.19
Global, days: 90
Region: Foot & ankle

Drawn from CMSAAPC

Documentation requirements

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

Source · Editorial brief grounded in 5 cited references ↓

Specify the exact phalanx involved (proximal, middle, or distal) and the toe number (first through fifth).
Document lesion type — bone cyst, enchondroma, exostosis, or other benign tumor — supported by preoperative imaging (X-ray, MRI, or CT) or histopathology.
Describe the surgical approach, extent of bony excision, and whether bone graft or bone void filler was used.
Record lesion dimensions (greatest diameter) in the operative note; vague entries like 'lesion excised' are an audit flag.
If multiple lesions or toes are treated, document each as a discrete pathological finding with separate anatomic sites.
Confirm medical necessity with clinical history — duration of symptoms, failed conservative treatment, or acute pathological fracture risk.

Applicable modifiers

Modifiers commonly billed with this code.

Source · AMA CPT modifier descriptors · CMS NCCI Policy Manual

22 Increased complexity 24 Unrelated E/M during global 25 Significant separate E/M 51 Multiple procedures 58 Staged or related 59 Distinct service 76 Repeat, same physician 77 Repeat, another physician 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 28108 covers excision of a bone cyst or benign tumor from one or more phalanges of the foot. The procedure involves surgical access to the affected toe bone, removal of the lesion, and typically bone grafting or packing of the resulting defect. It is most commonly performed by podiatrists and foot and ankle surgeons for conditions such as unicameral bone cysts, enchondromas, or subungual exostoses involving the toe phalanges.

The code carries a 90-day global period. All routine follow-up care, wound checks, dressing changes, and stitch removals through postoperative day 90 are bundled. Billing a separate E/M visit during the global window for a related complaint requires modifier 24; a separately identifiable E/M on the day of surgery requires modifier 25 appended to the E/M code.

Site of service matters here. HOPD and ASC payment rates differ substantially — see the Site of Service comparison on this page. When the procedure is performed on multiple toes or bilaterally, append modifier 59 or the appropriate laterality modifier (LT/RT) and document each discrete lesion separately in the operative note. Payers will look for lesion size, exact phalangeal location, and histopathologic or imaging confirmation in the record.

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 (4.19) is the surgeon's own effort — the figure physician pay and productivity targets are built on. The total RVU (12.91) adds practice overhead and malpractice, and is what drives the Medicare payment below.

Work RVU	4.19
Practice expense RVU	8.3
Malpractice RVU	0.42
Total RVU	12.91
Medicare national rate	$431.21
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	$431.21
HOPD (APC 5112) Hospital outpatient department	$1,642.82
ASC (PI A2) Ambulatory surgical center (freestanding)	$872.87

Common denial reasons

The recurring reasons claims for CPT 28108 get rejected.

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

Operative note lacks specific phalangeal location and lesion size, triggering a medical necessity denial.
Procedure billed without supporting imaging or pathology to substantiate a bone cyst or benign tumor diagnosis.
Modifier 59 or LT/RT missing when multiple toes treated on the same date, causing the additional unit to bundle and deny.
Related E/M visit billed during the 90-day global period without modifier 24, denied as included in the global.
ICD-10 diagnosis code mismatched to the site — using a finger/hand cyst code instead of a toe/foot phalanx code.

Frequently asked questions

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

01Does CPT 28108 include bone grafting if performed at the same session?

Bone grafting to fill the excision defect is generally considered integral to the procedure when performed at the same site. Billing a separate bone graft code alongside 28108 for the same lesion site risks bundling denial. If an autograft harvest from a distinct site is performed, document separately and review NCCI edits before billing an additional graft code.

02How do you bill when bone cysts are excised from two different toes on the same foot?

Bill 28108 for the primary lesion and append modifier 59 to the second unit to indicate a distinct anatomical site. Each lesion must be documented separately in the operative note with its own phalangeal location and pathological description. Without that documentation, the second unit will deny as a duplicate.

03What ICD-10 codes support 28108?

Common supporting diagnoses include M85.37x (solitary bone cyst, foot and toes), D16.3x (benign neoplasm of short bones of foot), and M92.7x (juvenile osteochondrosis of metatarsus and phalanges). Match the laterality suffix precisely — auditors flag nonspecific codes on a laterality-specific procedure.

04Can 28108 be billed same-day as a wound closure or soft-tissue excision on the same toe?

Check the NCCI procedure-to-procedure (PTP) edits before billing any same-day code on the same toe. Wound closure integral to the osseous excision is bundled. A soft-tissue lesion excision on a clearly separate site may be separately reportable with modifier 59, but the operative note must document distinct anatomic sites and pathology.

05What modifier applies if a planned 28108 is terminated after anesthesia induction but before the excision is completed?

Use modifier 74 when the procedure is discontinued after anesthesia administration has begun. Modifier 73 applies if the case is stopped before anesthesia. Document the reason for termination and the point at which the procedure was halted.

06Is 28108 subject to SNF consolidated billing?

Yes. CMS includes foot and toe excision procedures on the SNF consolidated billing list. If the patient is in a Medicare Part A SNF stay, the Part A payment generally covers the procedure and it cannot be billed separately to Part B unless a specific exclusion applies. Confirm the patient's SNF status before billing.

Sources & references

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

Mira Scribe

Mira's AI scribe captures the phalangeal level (proximal/middle/distal), toe number, lesion type and size, surgical approach, and whether bone graft was used — pulling these directly from dictation and populating the operative note fields that auditors check first. That prevents the most common denial on this code: a vague note that fails to establish medical necessity or anatomic specificity.

See how Mira captures CPT 28108 documentation