Soft tissue repair · Foot & ankle

28171

Surgical removal of a tumor originating in the tarsal bones of the foot, including the surrounding tissue margin; performed as radical resection when malignancy is confirmed.

Verified May 8, 2026 · 5 sources ↓

Medicare
$1,012.38
Total RVUs
30.31
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 which tarsal bone(s) are involved by name (calcaneus, talus, navicular, cuboid, medial/intermediate/lateral cuneiform)
  • State whether the resection was radical (malignant, wide-margin) or excisional (benign) and document the clinical basis for that determination
  • Record pre-operative imaging findings (MRI, CT, plain film) and correlate with operative findings
  • Document the extent of tissue margins excised and whether intraoperative frozen sections were performed
  • Include pathology requisition and link the final pathology report to the operative note
  • Identify laterality (left vs. right foot) explicitly in the operative note and on the claim

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 5 cited references ↓

CPT 28171 covers surgical excision of a tumor arising from the tarsal bones — the calcaneus, talus, navicular, cuboid, or cuneiforms. For malignant lesions, the resection is radical: the surgeon removes the tumor along with a wide margin of healthy bone and soft tissue to eliminate residual disease. For benign lesions, a less extensive excision may be appropriate, but the tarsal location still demands careful dissection around adjacent tendons, nerves, and vascular structures.

The 90-day global period means that all routine post-operative care from the day before surgery through day 90 is bundled into the payment. Any encounter in that window for a reason unrelated to the tarsal tumor resection requires modifier 24 (E/M) or modifier 79 (unrelated procedure). If the patient returns for a complication requiring a return to the OR for a related reason — wound dehiscence, hardware failure — use modifier 78.

Pathology is a separate billable service and is not bundled into 28171. Imaging obtained to evaluate the tumor pre-operatively or to confirm margins intraoperatively is also separately reportable. When the same surgeon performs a second distinct foot procedure on the same date, modifier 51 applies to the lower-valued code. Document laterality (LT/RT) on every claim.

RVU & reimbursement

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

Source · CMS Physician Fee Schedule, RVU26A · January 2026

Work RVU16
Practice expense RVU10.91
Malpractice RVU3.4
Total RVU30.31
Medicare national rate$1,012.38
Global period90 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

SettingMedicare rate (national)
Office (PFS non-facility)
Procedure performed in physician's office
$1,012.38
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 28171 get rejected.

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

  • Missing or mismatched ICD-10 diagnosis — payers require a bone tumor or neoplasm code (e.g., C40.3x, D16.3x) that directly supports tarsal resection
  • Laterality omitted from the claim; absence of LT or RT modifier triggers automatic denial on many payer edits
  • Radical resection billed without operative documentation supporting wide-margin excision, causing downcoding or medical necessity denial
  • Separate billing of incision-and-drainage or soft-tissue debridement performed in the same field during the same session — NCCI bundles overlapping foot excision codes
  • Post-op E/M visits within the 90-day global period billed without modifier 24, resulting in global period denial

Frequently asked questions

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

01When does 28171 require modifier 22?
Use modifier 22 when the resection is substantially more complex than typical — for example, a malignant tarsal tumor with extensive neurovascular involvement requiring meticulous dissection or reconstruction. The operative note must quantify the additional time and complexity; without that, payers will strip the modifier.
02Can 28171 and 28173 be billed together on the same date?
Yes, if distinct tarsal and metatarsal tumors are resected in separate anatomic sites during the same session. Attach modifier 51 to 28173 (the lower-valued code) and modifier 59 if needed to clarify separate lesions. Document each tumor's location and histology independently.
03Is pathology included in the 28171 payment?
No. Pathologic examination of the resected specimen is separately billable under the appropriate surgical pathology code (e.g., 88307 for bone tumor). The surgeon should document submission of specimen to pathology in the operative note.
04What ICD-10 codes are typically paired with 28171?
Malignant primary bone tumors map to C40.30–C40.32 (long bones of lower limb, which includes tarsals in some payer interpretations) or C40.30; malignant secondary (metastatic) lesions use C79.51. Benign bone tumors use D16.30–D16.32. Confirm your payer's accepted crosswalk — ICD-10 mismatch is the top denial driver for this code.
05How does the 90-day global period affect post-op oncology follow-up visits?
If the post-op visit is routine surgical follow-up, it is bundled — no separate E/M. If the visit addresses a new oncology concern or a condition unrelated to the foot surgery, bill the E/M with modifier 24 and document the distinct medical reason clearly in the note.
06Is 28171 payable in an ASC setting?
Yes. CMS assigns 28171 a J1 status indicator under OPPS, and CMS publishes an ASC payment rate for this code — see the Site of Service comparison table on this page. Verify the patient's anesthesia and post-op monitoring needs before scheduling in an ASC, as complex malignant resections may require hospital-based resources.

Mira AI Scribe

Mira's AI scribe captures the tarsal bone(s) resected by name, the surgeon's characterization of the resection extent (radical vs. excisional), margin width documented intraoperatively, laterality, and whether pathology was sent. This prevents the two most common audit flags: an operative note that names only 'tarsal tumor' without specifying the bone, and a radical-resection claim unsupported by documentation of wide-margin technique.

See how Mira captures CPT 28171 documentation

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