Midfoot capsulotomy combined with tendon lengthening, typically performed to correct clubfoot or midfoot deformity by releasing the joint capsule and surgically lengthening a contracted tendon.

Verified May 8, 2026 · 6 sources ↓

Medicare: $1,123.61
Total RVUs: 33.64
Global, days: 90
Region: Foot & ankle

Drawn from AAPCHighmarkbcbswvFastrvuNIHFindacode

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 joint capsule released by anatomic name (e.g., talonavicular) — 'midfoot capsule' alone is insufficient for audit.
Document the tendon(s) lengthened by name and the lengthening technique (Z-plasty, step-cut, percutaneous).
State the underlying diagnosis driving the procedure — congenital deformity, acquired contracture, or post-traumatic deformity — and link it to the ICD-10 code.
Record preoperative range-of-motion findings and deformity measurements to establish medical necessity.
Note whether the procedure is primary or following prior surgical intervention, which affects complexity and supports any modifier 22 claim.
Operative report must confirm both components — capsulotomy AND tendon lengthening — were performed; a note documenting only one component will not support 28261.

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 51 Multiple procedures 52 Reduced services 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 28261 covers a midfoot capsulotomy performed together with tendon lengthening. The surgeon opens the capsule of a midfoot joint — most commonly the talonavicular joint — and lengthens a contracted tendon to reduce deforming forces on the foot. The combined procedure addresses joint stiffness and tendon contracture in a single operative session, distinguishing it from a standalone capsulotomy (28270) or isolated tenotomy.

The primary indication is clubfoot or other congenital midfoot deformity, though the code also applies to acquired midfoot contracture from arthritis, injury, or prior surgical sequelae. Because 28261 is a combined code, payers such as Highmark BCBS have explicitly instructed that a capsulotomy and tendon procedure performed in the same operative area must be billed under the combined code — not itemized separately. Billing 28270 and a separate tenotomy code for the same site risks both NCCI bundling edits and payer-level downcoding.

The 90-day global period includes the day-before visit, the day of surgery, and all routine postoperative care through day 90. Unrelated E/M visits within that window require modifier 24. A new, unrelated procedure in the global period requires modifier 79. Modifier 78 applies only if the patient returns to the OR for a complication directly related to this surgery.

RVU & reimbursement

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

Source · CMS Physician Fee Schedule, RVU26A · January 2026

Work RVU	12.78
Practice expense RVU	18.67
Malpractice RVU	2.19
Total RVU	33.64
Medicare national rate	$1,123.61
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	$1,123.61
HOPD (APC 5112) Hospital outpatient department	$1,642.82
ASC (PI A2) Ambulatory surgical center (freestanding)	$872.87

Common denial reasons

The recurring reasons claims for CPT 28261 get rejected.

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

Billing capsulotomy (28270) and tenotomy separately when both were performed at the same midfoot site — payers require the combined code 28261.
ICD-10 diagnosis mismatch: submitting a toe-level deformity code against a midfoot procedure code triggers automated edits.
Missing medical necessity documentation — no preoperative functional assessment or failed conservative treatment noted in the record.
Unbundling: separately billing tendon lengthening when the operative note describes a single combined procedure at one site.
Global period violations: billing a related postoperative visit without modifier 24, or a related return-to-OR procedure without modifier 78.

Frequently asked questions

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

01Can I bill 28270 and a separate tenotomy code instead of 28261 when both are done at the same midfoot site?

No. When a capsulotomy and tendon lengthening are performed in the same midfoot operative area, payers — including Highmark BCBS in their published medical policy — require the combined code 28261. Itemizing the components separately will trigger bundling edits or downcoding to 28261 anyway.

02What diagnoses support 28261?

Clubfoot and other congenital midfoot deformities are the primary indications. Acquired midfoot contracture from post-traumatic deformity, arthritis-related stiffness, or residual deformity after prior surgery also supports the code — document the specific condition and failed conservative measures.

03How does 28261 differ from 28262?

28262 is reserved for extensive clubfoot repair that includes ankle joint capsulotomy and multiple tendon lengthenings — essentially a revision of failed prior clubfoot surgery with a broader operative scope. 28261 is the less extensive combined midfoot capsulotomy with tendon lengthening.

04What modifier applies if the patient returns to the OR within the 90-day global for a wound complication from this surgery?

Modifier 78 — unplanned return to the OR for a complication related to the original procedure. Do not use modifier 79 here; 79 is for a return-to-OR procedure that is unrelated to the original surgery.

05Is 28261 typically performed in an ASC or hospital outpatient setting?

Both settings are viable. ASC and HOPD payment rates differ — see the Site of Service comparison table on this page. Foot and ankle surgeons should verify the patient's payer-specific site-of-service policies, as some commercial payers restrict certain reconstructive foot procedures to hospital outpatient only.

06Does modifier 22 apply if the tendon lengthening was substantially more complex than typical?

Yes, if the work was genuinely increased — severe scarring from prior surgery, atypical anatomy, or significantly prolonged operative time. Attach a cover letter quantifying the additional time and complexity. Without that documentation, most payers will reject the upcharge.

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 joint capsule released by anatomic name, the tendon(s) lengthened and the technique used, the underlying deformity diagnosis, and preoperative range-of-motion findings — all from dictation. That prevents the most common denial: an operative note that documents only capsulotomy or only tendon work but not both, which forces a downcode from 28261 to a single-component code.

See how Mira captures CPT 28261 documentation