Surgical correction of hallux valgus (bunion) via proximal metatarsal osteotomy, involving realignment of the first metatarsal at its base with or without sesamoid removal.

Verified May 8, 2026 · 6 sources ↓

Medicare: $1,065.15
Total RVUs: 31.89
Global, days: 90
Region: Foot & ankle

Drawn from CMSCgsmedicareAAPCAcgme

Documentation requirements

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

Source · Editorial brief grounded in 6 cited references ↓

Preoperative weight-bearing radiographs documenting hallux valgus deformity with intermetatarsal angle measurement
Operative note specifying that a proximal metatarsal osteotomy was performed, not a distal or shaft-level cut
Documentation of fixation method used (e.g., plate, screw, staple) and osteotomy configuration
Indication for proximal approach — note severity of deformity and why distal correction was insufficient
If sesamoidectomy performed, document separately and support medical necessity for removal
Conservative treatment history (orthotics, shoe modifications, injections) supporting surgical necessity

Applicable modifiers

Modifiers commonly billed with this code.

Source · AMA CPT modifier descriptors · CMS NCCI Policy Manual

22 Increased complexity 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 80 Assistant surgeon AS PA/NP/CNS assistant

What this code covers

Source · Editorial summary grounded in 6 cited references ↓

CPT 28295 describes a bunion correction procedure in which the surgeon cuts and repositions the proximal first metatarsal to reduce the intermetatarsal angle and correct the hallux valgus deformity. This approach is chosen over distal osteotomies when the deformity is moderate to severe, requiring a more powerful angular correction at the base of the metatarsal. The procedure may also include removal of the medial eminence and, when indicated, sesamoidectomy.

The 90-day global period covers all routine postoperative care through day 90. That includes wound checks, hardware monitoring visits, and dressing changes. Anything unrelated to the bunion correction billed during that window requires modifier 24 or 25. Complications requiring a return to the OR for a related procedure use modifier 78; an unrelated procedure in the global window uses modifier 79.

This code sits in the repair, revision, and reconstruction category for the foot and toes. Podiatry accounts for the dominant billing share per CMS Physician Fee Schedule data. The significant payment differential between HOPD and ASC sites means site-of-service decisions directly affect facility economics — see the Site of Service comparison table.

RVU & reimbursement

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

Source · CMS Physician Fee Schedule, RVU26A · January 2026

Work RVU	8.36
Practice expense RVU	22.31
Malpractice RVU	1.22
Total RVU	31.89
Medicare national rate	$1,065.15
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	$1,065.15
HOPD (APC 5113) Hospital outpatient department	$3,342.87
ASC (PI G2) Ambulatory surgical center (freestanding)	$1,644.87

Common denial reasons

The recurring reasons claims for CPT 28295 get rejected.

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

Operative note says 'standard bunionectomy' without specifying proximal osteotomy — auditors cannot confirm the code level
Missing preoperative radiographic measurements to support severity requiring proximal correction
28308 bundling conflict when reported same-day without appropriate modifier — see 2026 NCCI edit pairing
Medical necessity denied when conservative treatment history is absent or inadequately documented
Global period violation — routine post-op visit billed without modifier 24 during the 90-day window

Frequently asked questions

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

01What distinguishes 28295 from 28292 or 28296?

28295 requires a proximal metatarsal osteotomy. 28292 (Keller-type procedure) involves resection arthroplasty of the proximal phalanx base. 28296 involves a distal metatarsal osteotomy such as a chevron. The osteotomy location documented in the operative note drives the code — proximal metatarsal cuts go to 28295.

02Can 28295 and 28308 be billed together?

There is an active NCCI edit pairing 28295 and 28308 effective 2026-01-01. If both are clinically distinct and separately documented, modifier 59 may allow separate payment, but your operative note must support that the metatarsal osteotomy and the toe deformity correction were independent procedures, not overlapping components of a single correction.

03Does the 90-day global include postoperative hardware removal if needed?

Routine hardware removal within the global period is generally included. If the removal is an unplanned return to the OR for a complication related to the original surgery, use modifier 78. If hardware removal is performed after the global period expires, bill the appropriate removal code without a modifier.

04Is modifier 50 appropriate for bilateral hallux valgus corrections at the same session?

Yes. If both feet are corrected in the same operative session, append modifier 50 to 28295 and bill one line. Some payers prefer LT and RT on separate lines — verify your payer's bilateral billing preference before submitting.

05What ICD-10 codes support medical necessity for 28295?

M20.11 (hallux valgus, right foot) and M20.12 (hallux valgus, left foot) are the primary diagnoses. Document symptom severity, prior conservative care, and functional limitation in the medical record to survive a medical necessity review — the ICD-10 code alone is not sufficient.

06Can modifier 22 be used if the correction was unusually complex?

Yes, but only when the work substantially exceeded the typical procedure — for example, severe deformity with revision of prior hardware, or abnormal anatomy requiring extended operative time. Document specific factors in the operative note and attach a cover letter. Expect payer scrutiny and potential audit.

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 osteotomy level (proximal versus distal), fixation construct, intermetatarsal angle correction, sesamoid status, and any concomitant procedures from the surgeon's dictation. This prevents the single most common audit flag for 28295: an operative note that documents a bunion correction without confirming the proximal metatarsal osteotomy that distinguishes this code from lower-complexity alternatives.

See how Mira captures CPT 28295 documentation