Surgical repair of a flexor tendon in the foot — primary or secondary — without the use of a free graft, reported per tendon.

Verified May 8, 2026 · 6 sources ↓

Medicare: $504.35
Total RVUs: 15.1
Global, days: 90
Region: Foot & ankle

Drawn from CMSPodiatrymAAOS

Documentation requirements

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

Source · Editorial brief grounded in 6 cited references ↓

Specify which tendon was repaired by name (e.g., flexor hallucis longus, posterior tibial, flexor digitorum longus) — 'foot tendon' alone is insufficient.
Confirm the anatomic site is within the foot, not the ankle or lower leg, to justify 28200 over codes in the 27600s.
State whether this is a primary repair (acute) or secondary repair (delayed/revision) to support medical necessity.
Document the repair technique in detail, including suture type, number of strands, and any anchor use — note that anchors are bundled and not separately reportable.
If multiple tendons are repaired in the same session, identify each tendon individually to support separate-line billing with modifier 51.
Record intraoperative findings, including the extent of tendon injury (partial vs. complete rupture), to substantiate complexity and any modifier 22 claim.

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 57 Decision for surgery 58 Staged or related 59 Distinct service 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 28200 covers operative repair of a flexor tendon within the foot, whether performed as a primary repair at the time of injury or as a secondary repair after a failed initial attempt or delayed presentation. The code is used without a free graft; if a free tendon graft is required, a different code applies. It is reported per tendon, so multiple tendon repairs in the same session can each be reported separately with modifier 51 appended to the additional procedure(s).

Common clinical scenarios include rupture or laceration of the flexor hallucis longus (FHL) within the foot, posterior tibial tendon repair at the foot level, and flexor digitorum repairs. Site matters: if the repair is performed at the ankle or lower leg rather than within the foot proper, a different code family applies (e.g., 27658). Bone anchor use is bundled into the surgical allowance and is not separately billable. The 90-day global period means all routine post-op management through day 90 is included in the payment — unrelated E/M visits during that window require modifier 24.

When 28200 is billed same-day with a bone procedure such as 28122, NCCI edits must be checked. In documented scenarios where the two procedures are distinct and separately identifiable, modifier 59 appended to 28200 is the mechanism to bypass the bundling edit. Podiatry is the dominant billing specialty for this code.

RVU & reimbursement

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

Source · CMS Physician Fee Schedule, RVU26A · January 2026

Work RVU	4.62
Practice expense RVU	9.92
Malpractice RVU	0.56
Total RVU	15.1
Medicare national rate	$504.35
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	$504.35
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 28200 get rejected.

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

Site-of-service mismatch — operative note describes repair at the ankle or lower leg level, which maps to a different code family.
Bundling denial when 28200 is billed alongside a same-day bone procedure without modifier 59 and supporting documentation of distinct, separately identifiable services.
Insufficient tendon specificity — operative notes that reference 'foot tendon repair' without naming the tendon flag for medical necessity reviews and audits.
Global period conflict — post-op E/M visits billed without modifier 24 when they fall within the 90-day global and are related to the procedure.
Missing or inadequate support for modifier 22 when increased complexity is claimed — documentation must explicitly describe what made the case substantially more difficult than typical.

Frequently asked questions

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

01Can I bill 28200 for a flexor hallucis longus repair done at the ankle?

No. 28200 is limited to repairs performed within the foot. FHL repair at the ankle or lower leg level maps to the 27658 code family. The anatomic site in your operative note determines which code is correct — document it explicitly.

02Is bone anchor use separately billable with 28200?

No. Anchor use is bundled into the surgical allowance for 28200. Do not report a separate supply or implant code for the anchor — payers will deny or recoup it.

03If I repair two flexor tendons in the same session, how do I bill?

Report 28200 for the first tendon, then report 28200 again with modifier 51 for each additional tendon. Name each tendon separately in the operative note to support the multi-line billing.

04When do I need modifier 59 with 28200?

When 28200 is billed same-day with a bone procedure — such as 28122 — and an NCCI edit bundles the pair, modifier 59 appended to 28200 signals a distinct, separately identifiable service. Back it with documentation that clearly separates the indications and intraoperative work for each procedure.

05What modifier applies if the patient returns to the OR within the 90-day global for a related tendon complication?

Use modifier 78. That signals an unplanned return to the OR for a procedure related to the original surgery within the global period. Do not use modifier 79, which is for unrelated procedures during the global.

06Does the 90-day global period affect how I bill post-op E/M visits?

Yes. Routine post-op E/M visits within 90 days are included in the 28200 payment and cannot be billed separately. If a visit is for a condition unrelated to the tendon repair, append modifier 24 to the E/M code and document the unrelated reason clearly.

07Can modifier 22 be used for a particularly complex secondary repair with significant scarring?

Yes, but documentation must explicitly describe what elevated the complexity beyond a typical repair — adhesion takedown extent, compromised tissue quality, prolonged operative time, or prior failed repair. A vague note referencing 'difficult dissection' is unlikely to survive audit or appeal.

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 tendon name, anatomic location within the foot, primary versus secondary repair designation, repair technique, suture configuration, and any anchor use from dictation. It flags when operative language describes the repair at the ankle or leg level — the single most common reason 28200 is coded incorrectly and triggers a site-of-service denial. When multiple tendons are documented, the scribe surfaces each one for individual line-item review with modifier 51.

See how Mira captures CPT 28200 documentation