Surgical tenolysis of multiple extensor tendons of the foot, freeing them from adhesions to restore gliding function and reduce pain.

Verified May 8, 2026 · 6 sources ↓

Medicare: $665.35
Work RVU: 4.55
Global, days: 90
Region: Foot & ankle

Drawn from CMSAAPCAxogenincGenhealth

Documentation requirements

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

Source · Editorial brief grounded in 6 cited references ↓

Identify each extensor tendon released by anatomic name (e.g., extensor hallucis longus, extensor digitorum longus)
Describe the nature and location of adhesions and the clinical indication for tenolysis
Document intraoperative confirmation that tendon gliding was restored following release
Record that conservative measures (physical therapy, splinting, injections) were attempted and failed prior to surgery
Specify surgical approach, incision location(s), and whether separate incisions were used for each tendon
Include post-operative plan and functional status assessment to support medical necessity

Applicable modifiers

Modifiers commonly billed with this code.

Source · AMA CPT modifier descriptors · CMS NCCI Policy Manual

22 Increased complexity 50 Bilateral procedure 51 Multiple procedures 58 Staged or related 59 Distinct service 79 Unrelated during global LT Left side RT Right side XS Separate structure

What this code covers

Source · Editorial summary grounded in 6 cited references ↓

CPT 28226 covers tenolysis of multiple extensor tendons of the foot — a procedure that surgically frees two or more extensor tendons from restrictive scar tissue or adhesions. This is the multiple-tendon counterpart to 28225 (single extensor tendon). The distinction matters: if only one extensor tendon is released, 28225 applies; when two or more are addressed, 28226 is correct. Confusing the two is a common coding error and a straightforward audit target.

The procedure carries a 90-day global period. All routine post-op visits, wound checks, and related services within that window are bundled — bill with modifier 24 or 79 only for unrelated E/M or unrelated procedures. If the surgeon staged a secondary procedure related to this release, modifier 58 applies. When the same extensor tenolysis is performed bilaterally in the same session, append modifier 50 and confirm the payer accepts bilateral billing for this code before submission.

Flexor tenolysis of the foot codes (28220, 28222) are anatomically distinct and not interchangeable. Do not substitute or cross-bill between flexor and extensor families. Operative notes must name which tendons were lysed — extensor hallucis longus, extensor digitorum longus, extensor digitorum brevis, etc. — and describe the adhesion burden and technique. Notes that simply state 'multiple tendons released' without anatomic specificity routinely draw additional documentation requests.

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 (4.55) is the surgeon's own effort — the figure physician pay and productivity targets are built on. The total RVU (19.92) adds practice overhead and malpractice, and is what drives the Medicare payment below.

Work RVU	4.55
Practice expense RVU	14.39
Malpractice RVU	0.98
Total RVU	19.92
Medicare national rate	$665.35
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	$665.35
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 28226 get rejected.

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

Operative note names only one tendon released — payer downcodes to 28225 (single tendon)
Medical necessity not established: no documentation of failed conservative treatment before surgery
Incorrect code family billed — flexor tenolysis codes (28220/28222) submitted when extensor tendons were treated
Bilateral procedure submitted without modifier 50 or without individual payer authorization for bilateral billing
Post-op E/M visits billed without modifier 24 during the 90-day global period, triggering automatic bundling denial

Frequently asked questions

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

01What separates 28226 from 28225?

28225 is for a single extensor tendon release; 28226 applies when two or more extensor tendons of the foot are released in the same operative session. Document each tendon by name in the operative report — that's the proof that 28226, not 28225, is correct.

02Can 28226 be billed with flexor tenolysis codes (28220 or 28222) on the same day?

Yes, if both extensor and flexor tendon releases are performed in the same session, both code families can be reported. Append modifier 51 to the lower-value code and document separate anatomic structures to support distinct procedural services.

03Is modifier 50 appropriate for bilateral extensor tenolysis?

If the same procedure is performed on both feet in the same session, modifier 50 is appropriate. Verify individual payer policy — some commercial payers require LT and RT on separate lines rather than a single-line modifier 50 submission.

04What ICD-10 diagnoses typically support medical necessity for 28226?

Common supporting diagnoses include adhesive tenosynovitis of the foot, post-traumatic tendon adhesions, and extensor tendon contracture. The record should show prior failed conservative management regardless of which diagnosis code is used.

05How does the 90-day global period affect post-op billing for 28226?

Routine follow-up visits within 90 days of surgery are bundled. To bill a post-op E/M for a problem unrelated to the tenolysis, append modifier 24 with documentation confirming the visit addressed a separate condition. An unrelated procedure in the global window needs modifier 79.

06When would modifier 22 be appropriate for 28226?

Modifier 22 applies when the procedure required substantially greater work than typical — for example, severe scarring from prior surgery or significant tissue distortion requiring extended operative time. Support it with a separate written justification and document the added complexity explicitly in the operative note.

Sources & references

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

Mira Scribe

Mira's AI scribe captures the names of each extensor tendon lysed, the intraoperative description of adhesion extent and location, incision approach, and confirmation of restored tendon excursion — the specific details auditors look for when validating the 'multiple tendons' threshold for 28226 over 28225. Missing tendon-level documentation is the primary reason payers downcode to the single-tendon code (28225), cutting reimbursement.

See how Mira captures CPT 28226 documentation