Surgical removal of a deep foreign body from the foot, requiring dissection beyond the subcutaneous layer.

Verified May 8, 2026 · 4 sources ↓

Medicare: $456.92
Work RVU: 4.66
Global, days: 90
Region: Foot & ankle

Drawn from CMSPodiatrym

Documentation requirements

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

Source · Editorial brief grounded in 4 cited references ↓

Tissue depth explicitly documented — object location relative to subcutaneous layer, fascia, tendon, or bone
Operative note describes the dissection technique used to reach the foreign body
Type, size, and material of foreign body (e.g., glass shard, metal fragment, wooden splinter) documented and retained as specimen or described
Anatomical location within the foot specified (plantar, dorsal, heel, toe, etc.)
Pre-op imaging or clinical findings that confirmed depth and guided surgical approach
Wound closure method and depth of closure documented if layered repair performed

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 78 Unplanned return — related 79 Unrelated during global LT Left side RT Right side XS Separate structure

What this code covers

Source · Editorial summary grounded in 4 cited references ↓

CPT 28192 covers deep foreign body removal from the foot — meaning the object is seated below the subcutaneous tissue and requires operative dissection to retrieve. This distinguishes it from simple subcutaneous removal (28190) and positions it as a facility-eligible surgical procedure carrying a 90-day global period.

The 90-day global covers the surgery itself, the day-before preoperative visit, and all routine postoperative care through day 90. If a separate, unrelated condition is treated during that window, append modifier 79. A return to the OR for a related complication — retained fragment, wound dehiscence — uses modifier 78.

Depth documentation is the single biggest audit target for this code. Operative notes that describe location vaguely (e.g., 'plantar foot') without specifying tissue plane, anatomical depth relative to fascia or tendon, and dissection technique are routinely flagged. If the foreign body was subcutaneous, the correct code is 28190 or 10120/10121 — auditors and payers know the distinction and will downcode without explicit depth language.

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 (4.66) is the surgeon's own effort — the figure physician pay and productivity targets are built on. The total RVU (13.68) adds practice overhead and malpractice, and is what drives the Medicare payment below.

Work RVU	4.66
Practice expense RVU	8.56
Malpractice RVU	0.46
Total RVU	13.68
Medicare national rate	$456.92
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	$456.92
HOPD (APC 5072) Hospital outpatient department	$1,687.37
ASC (PI A2) Ambulatory surgical center (freestanding)	$742.04

Common denial reasons

The recurring reasons claims for CPT 28192 get rejected.

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

Depth insufficiently documented — payer downcodes to 28190 or 10120 when operative note lacks explicit deep-tissue language
Billed same-day as wound closure or debridement codes without a modifier establishing distinct procedural service
Wrong code selected — 28192 billed when foreign body was subcutaneous, making 28190 or 10120 the correct choice
Missing or vague foreign body description — no laterality, no tissue depth, no object type documented in the operative note
Global period conflict — postoperative follow-up billed without modifier 24 during the 90-day global

Frequently asked questions

Source · Generated from the editorial pipeline, verified against 4 cited references ↓

01What separates CPT 28192 from 28190?

Depth. Code 28190 covers subcutaneous foreign body removal. Code 28192 applies when the object is deep to the subcutaneous layer — below fascia, adjacent to tendon, or near bone — and operative dissection was required to reach it. If your note doesn't explicitly state the object was deep, expect a downcode to 28190.

02When should I use 10120 or 10121 instead of 28192?

Use 10120 (simple) or 10121 (complicated) for subcutaneous foreign body removal from any body site. Reserve 28192 specifically for deep foot foreign body removal. If the object was in the dermis or subcutaneous fat of the foot, 10120/10121 is more appropriate than 28192.

03The patient returns during the 90-day global with a retained fragment — what modifier applies?

Modifier 78. That's an unplanned return to the OR for a complication related to the original procedure. If the return is for a completely unrelated foot problem, use modifier 79 instead. Don't mix them up — inverting 78 and 79 is a common audit finding.

04Can I bill an E/M on the same day as 28192?

Only if the E/M addressed a separately identifiable problem beyond the decision to perform the foreign body removal. Append modifier 25 to the E/M code and document the distinct medical decision-making in the visit note — not just the surgical plan.

05Is laterality required for 28192?

Yes. Append LT or RT to specify which foot. Claims without laterality modifiers are increasingly flagged by commercial payers and Medicare administrative contractors, particularly for bilateral encounters.

06Does the 90-day global include imaging ordered postoperatively to confirm complete removal?

Imaging interpretation (radiology read) is not bundled into the surgical global — bill it separately. However, the ordering visit for routine post-op follow-up is bundled. If the imaging leads to a new surgical decision unrelated to the original procedure, modifier 79 may apply to any subsequent procedure.

Sources & references

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

01CMS Physician Fee Schedule 2026
02
cms.gov
https://www.cms.gov/files/document/2025nccimedicarepolicymanualcompletepdf.pdf
03
cms.gov
https://www.cms.gov/medicare/coding-billing/national-correct-coding-initiative-ncci-edits
04
podiatrym.com
https://www.podiatrym.com/search3.cfm?id=31300

Mira Scribe

Mira's AI scribe captures tissue depth, dissection path, anatomical location, and foreign body description directly from your operative dictation — the exact language auditors look for to justify 28192 over a subcutaneous-level code. That prevents the most common denial: a payer downcode to 28190 because the note didn't explicitly place the object below the subcutaneous layer.

See how Mira captures CPT 28192 documentation