Surgical removal of a foreign body lodged in subcutaneous tissue of the foot.

Verified May 8, 2026 · 6 sources ↓

Medicare: $239.48
Work RVU: 1.96
Global, days: 10
Region: Foot & ankle

Drawn from CMSAAPCTldsystemsPublicationsPayerprice

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 type of foreign body (glass, splinter, metal, etc.) and how it was identified (clinical exam, X-ray, ultrasound).
Document the anatomical location within the foot (plantar forefoot, heel, dorsum, hallux, etc.) and laterality.
Confirm the depth of the foreign body as subcutaneous — not deep to fascia or involving tendons or neurovascular structures.
Describe the surgical technique: incision size and location, method of foreign body identification and extraction, and wound closure.
Note whether imaging was used intraoperatively; if fluoroscopy or ultrasound guidance was used, those may be separately billable.
Document local anesthesia type if used — it's bundled, but its presence confirms the subcutaneous access approach.

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 52 Reduced services 59 Distinct service 76 Repeat, same physician 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 28190 covers subcutaneous foreign body removal from the foot — think glass, splinters, metal fragments, or gravel that has embedded below the dermis but not into deeper fascial or tendinous layers. The procedure typically requires a skin incision to access and extract the object, followed by wound closure. Local anesthesia (infiltration, digital block, or topical) is bundled into the global surgical package for this code and cannot be billed separately.

Depth drives code selection in this family. 28190 is subcutaneous only. If the object is below subcutaneous tissue, bill 28192 (deep). If the removal is complicated — extensive dissection, neurovascular proximity, imaging guidance, or unusual difficulty — bill 28193. Misclassifying subcutaneous as deep, or using a generic soft-tissue removal code like 10120 when a foot-specific code exists, are the two fastest routes to a payer audit.

The global period is 10 days. Routine wound checks and suture removal within that window are not separately billable. An E/M visit for an unrelated problem during the 10-day global requires modifier 24.

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 (1.96) is the surgeon's own effort — the figure physician pay and productivity targets are built on. The total RVU (7.17) adds practice overhead and malpractice, and is what drives the Medicare payment below.

Work RVU	1.96
Practice expense RVU	5
Malpractice RVU	0.21
Total RVU	7.17
Medicare national rate	$239.48
Global period	10 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	$239.48
HOPD (APC 5071) Hospital outpatient department	$723.47
ASC (PI P3) Ambulatory surgical center (freestanding)	$167.84

Common denial reasons

The recurring reasons claims for CPT 28190 get rejected.

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

Wrong code level — billing 28190 when operative note describes dissection below subcutaneous tissue, which maps to 28192 or 28193.
Using 10120 (generic subcutaneous foreign body removal) instead of the site-specific 28190, triggering a code substitution or downcoding by the payer.
Missing laterality modifier (LT or RT) on payers that require it, causing claim rejection.
Separate billing for local anesthesia or digital block, which is bundled into the 28190 global surgical package.
E/M billed same-day without modifier 25 when a separate, distinctly documented decision-making encounter occurred on the same date.

Frequently asked questions

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

01What's the difference between 28190, 28192, and 28193?

Depth and complexity. 28190 is subcutaneous. 28192 (deep) applies when the foreign body is below subcutaneous tissue, in deeper fascial or muscular planes. 28193 is for complicated removals — extensive dissection, neurovascular involvement, or objects requiring imaging guidance. 28192 and 28193 carry 90-day global periods; 28190 carries only 10 days.

02When should I use 10120 instead of 28190?

Don't use 10120 for foot foreign body removals when a site-specific code exists. CPT Assistant (December 2013) distinguishes 10120 (generic subcutaneous incision and removal) from 28190 based on anatomical specificity. Use 28190 for foot procedures — payers familiar with this distinction may deny or substitute 10120 claims when the foot is the documented site.

03Is local anesthesia separately billable with 28190?

No. Local infiltration, digital blocks, and topical anesthesia are bundled into the 28190 global surgical package per CPT guidelines and CMS. Billing them separately will be denied as included services.

04Can I bill an E/M on the same day as 28190?

Yes, but only if the E/M represents a separately identifiable service beyond the decision to perform the removal. Add modifier 25 to the E/M code and document the distinct medical decision-making in your note. Without modifier 25, the E/M will be bundled into the procedure.

05Do I need laterality modifiers for 28190?

Many payers require LT or RT for unilateral foot procedures. Medicare doesn't mandate laterality modifiers for 28190, but commercial payers and some MACs do. Append LT or RT as a default practice to avoid rejections, especially in high-volume settings.

06What if I have to return to remove a retained fragment during the 10-day global?

If the return procedure is related to the original removal (retained fragment from the same event), append modifier 78 to the repeat procedure code. If it's an unrelated foreign body on the same foot, use modifier 79. Do not bill the repeat procedure without a modifier — it will deny as included in the global.

07Can 28190 be billed bilaterally?

Yes, if foreign bodies are removed from both feet in the same session. Append modifier 50 for bilateral billing, or bill the code twice with LT and RT modifiers depending on payer preference. Verify with the specific payer — some require 50, others prefer line-item billing with laterality modifiers.

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 foreign body type, confirmed anatomical depth (subcutaneous), exact foot location and laterality, incision approach, extraction method, and wound closure from dictation. That depth documentation is the single fact that separates 28190 from 28192 and 28193 — and the first thing an auditor checks. Without it, expect downcoding or a request for operative note review.

See how Mira captures CPT 28190 documentation