Open surgical release of one or more extrinsic tendons of the foot, performed to restore motion or relieve contracture.

Verified May 8, 2026 · 6 sources ↓

Medicare: $543.43
Work RVU: 5.62
Global, days: 90
Region: Foot & ankle

Drawn from CMSAAPCAAOS

Documentation requirements

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

Source · Editorial brief grounded in 6 cited references ↓

Identify the specific tendon(s) released by name (e.g., flexor hallucis longus, flexor digitorum longus, extensor digitorum longus) — 'foot tendons' alone is insufficient for audit defense.
Document the indication: contracture severity, failed conservative treatment, functional limitation, or underlying diagnosis (e.g., equinus deformity, Charcot foot, post-traumatic adhesion).
Specify the surgical approach and technique — open release, Z-lengthening, or tenotomy — and confirm the anatomic location (plantar, dorsal, digit involved).
If billing same-day with debridement or other foot procedure codes, document that tendon release was performed at a distinct anatomic site or as a separately identifiable procedure to support modifier 59 or XS.
Record pre- and intraoperative range-of-motion findings to establish medical necessity and document the functional outcome of the release.
Note any concurrent procedures performed (e.g., osteotomy, arthrodesis) and confirm each meets independent reporting criteria under NCCI PTP rules.

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 59 Distinct service LT Left side RT Right side 78 Unplanned return — related 79 Unrelated during global 80 Assistant surgeon AS PA/NP/CNS assistant XS Separate structure

What this code covers

Source · Editorial summary grounded in 6 cited references ↓

CPT 28222 covers open release of foot tendons — typically the flexor or extensor tendons — when contracture, scarring, or spasticity limits function and conservative measures have failed. The procedure involves surgical exposure of the affected tendon(s) and division or lengthening to restore passive range of motion. Common indications include equinus contracture, hammertoe-related tendon tightness, diabetic Charcot foot sequelae, and post-traumatic adhesions.

This code carries a 90-day global period under CMS. That window covers the operative encounter, the day-before visit if applicable, and all routine follow-up through post-op day 90. Separate E/M visits during the global for unrelated conditions require modifier 24; a separately identifiable E/M on the day of surgery requires modifier 25.

Billing 28222 alongside debridement codes (e.g., 28003, 28005) triggers NCCI PTP edits — particularly relevant in diabetic foot cases. When tendon release is performed as a distinct procedure separate from debridement at a different anatomic site, modifier 59 or XS documents that separation. Check the current NCCI PTP table before billing; indicator '0' pairs cannot be bypassed with any modifier.

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 (5.62) is the surgeon's own effort — the figure physician pay and productivity targets are built on. The total RVU (16.27) adds practice overhead and malpractice, and is what drives the Medicare payment below.

Work RVU	5.62
Practice expense RVU	10.03
Malpractice RVU	0.62
Total RVU	16.27
Medicare national rate	$543.43
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	$543.43
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 28222 get rejected.

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

Operative note lacks specific tendon identification — generic 'tendon release' language fails medical necessity review and audits.
NCCI PTP bundle denial when 28222 is billed same-day with debridement codes (28003, 28005) without modifier 59 or XS and supporting documentation of distinct anatomic sites.
Missing conservative treatment history: payers deny tendon release claims when the record shows no trial of physical therapy, stretching, orthotics, or serial casting prior to surgery.
Global period conflict: post-op E/M visits billed without modifier 24 during the 90-day global are denied as included services.
Diagnosis-code mismatch: ICD-10 codes that describe a condition not anatomically consistent with foot tendon release (e.g., knee or ankle-only codes) trigger claim edits.

Frequently asked questions

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

01What is the global period for CPT 28222?

90 days. All routine post-op visits, dressing changes, and stitch removals through day 90 are included. Bill unrelated E/M visits during that window with modifier 24.

02Can 28222 be billed with debridement codes on the same day?

Only with caution. NCCI PTP edits bundle 28222 with codes like 28003 and 28005. If the tendon release and debridement were performed at distinct anatomic sites, append modifier 59 or XS and document that separation in the operative note. A PTP indicator of '0' means no modifier can override the edit — verify the indicator before billing.

03Does 28222 cover multiple tendons, or do you bill it once per tendon?

28222 is reported once for the procedure regardless of how many tendons are released during the same operative session. If the work substantially exceeds the typical procedure, modifier 22 with supporting documentation is the correct path — not multiple units.

04Which ICD-10 codes support 28222?

Common supporting diagnoses include acquired deformities of the foot (M21.xx), contracture of muscle (M62.4x), equinus deformity (M21.37x), hammertoe (M20.4x), and post-traumatic or post-surgical adhesions. The diagnosis must be anatomically consistent with foot tendon pathology.

05Is modifier 51 needed when 28222 is billed with another foot procedure on the same day?

If 28222 is a secondary procedure to a primary foot surgery billed in the same session, modifier 51 signals multiple procedures to the payer and triggers the standard multiple procedure reduction. Confirm whether your payer follows CMS multiple procedure payment reduction rules or has a separate policy.

06What site-of-service difference should I expect between HOPD and ASC for this code?

There is a significant payment gap between hospital outpatient department and ASC settings for 28222 under CMS — see the site-of-service comparison table on this page. ASC is substantially lower. That differential is relevant when counseling patients on cost-sharing and when making facility decisions.

Sources & references

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

Mira Scribe

Mira's AI scribe captures the tendon name, surgical technique (e.g., Z-lengthening vs. tenotomy), anatomic location, pre-op contracture severity, and failed conservative measures directly from dictation. That specificity prevents the two most common denials: vague operative notes that fail medical necessity review and NCCI bundle disputes when release is performed alongside debridement in diabetic foot cases.

See how Mira captures CPT 28222 documentation