Open surgical treatment of a phalanx or phalangeal fracture involving any toe except the great toe, with internal fixation applied when indicated; reported per toe treated.

Verified May 8, 2026 · 6 sources ↓

Medicare: $573.49
Work RVU: 5.48
Global, days: 90
Region: Foot & ankle

Drawn from CMSFastrvuAbosPayerprice

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 toe and phalanx (proximal, middle, or distal) treated by name and digit number — use T1–T9 modifiers to match.
Document that open exposure was performed — describe the incision site, length, and approach to confirm this is not percutaneous pinning.
Record whether internal fixation was placed and, if so, the type and configuration (K-wire, mini-fragment screw, plate).
Include pre- and post-reduction imaging confirming fracture alignment and hardware position.
Note the indication for open treatment versus closed or percutaneous techniques (e.g., irreducible fracture, failed closed reduction, associated soft tissue injury).
If multiple lesser toes were treated, document each toe separately with distinct operative detail to support multiple units of 28525.

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 76 Repeat, same physician 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 28525 covers open reduction of a lesser toe phalanx fracture — any toe except the great toe — with internal fixation (K-wire, screw, or plate) when performed. The "each" descriptor means the code can be reported once per toe treated; if you treat two separate lesser toes in the same operative session, you report 28525 twice with the appropriate digit modifiers (T1–T9) and modifier 51.

This is a 90-day global procedure. All routine post-op visits, dressing changes, hardware monitoring, and pin removal are bundled through day 90. Any E&M for an unrelated condition during that window needs modifier 24. A staged or planned subsequent procedure in the global period requires modifier 58; an unplanned return to the OR for a related complication requires modifier 78.

Not to be confused with 28515 (closed treatment of lesser toe phalanx fracture without manipulation) or 28496/28505 (great toe percutaneous and open treatment, respectively). Selection between 28525 and percutaneous alternatives hinges on whether the skin was formally opened for direct fracture visualization, not merely on whether a pin was used.

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 (5.48) is the surgeon's own effort — the figure physician pay and productivity targets are built on. The total RVU (17.17) adds practice overhead and malpractice, and is what drives the Medicare payment below.

Work RVU	5.48
Practice expense RVU	11
Malpractice RVU	0.69
Total RVU	17.17
Medicare national rate	$573.49
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	$573.49
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 28525 get rejected.

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

Missing or incorrect digit modifier (T1–T9) — Medicare MUE values for toe procedures are set assuming one unit per digit, and omitting the modifier triggers MUE edits.
Upcoding from percutaneous pinning (28476 or similar) to 28525 when the operative note does not describe a formal open incision and direct fracture visualization.
Multiple units of 28525 billed without modifier 51 and individual digit modifiers when treating more than one lesser toe in the same session.
E&M service billed same-day without modifier 25 — if the decision to operate was made at that visit, modifier 57 is required for major surgery; 25 applies to minor surgical procedures.
Failure to append modifier 58 when a second open procedure (e.g., hardware removal or revision fixation) is performed as a planned staged procedure within the 90-day global period.

Frequently asked questions

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

01What is the difference between CPT 28525 and 28515?

28515 is closed treatment of a lesser toe phalanx fracture without manipulation. 28525 requires formal open surgical exposure with or without internal fixation. If you pinned a toe percutaneously without opening the skin for direct visualization, neither code may be correct — check 28476 for percutaneous fixation of a metatarsal fracture or the applicable lesser toe percutaneous code.

02Can I bill 28525 twice if I operated on two lesser toes during the same session?

Yes. The descriptor says 'each,' so report 28525 once per toe treated. Append modifier 51 to the lower-value unit and use distinct digit modifiers (T1–T9) on each line. Without the digit modifiers, Medicare MUE edits will reduce payment to one unit.

03Which digit modifiers apply to lesser toe procedures for Medicare?

Use T1–T9 per CMS NCCI policy: T1 = left foot second digit through T5 = left foot fifth digit; T6 = right foot second digit through T9 = right foot fifth digit. TA is reserved for the great toe and does not apply to 28525.

04Is hardware removal during the 90-day global period separately billable?

Routine hardware removal that is a planned part of the surgical episode is bundled in the 90-day global. If removal was planned at the time of the original surgery, use modifier 58 for the staged procedure. If removal is unplanned due to a complication, use modifier 78.

05What modifier do I use if I perform an E&M and then take the patient to surgery the same day?

For a major surgery with a 90-day global, the decision-for-surgery E&M on the day of or the day before the procedure requires modifier 57. Modifier 25 applies to minor surgical procedures (0 or 10-day global), not to 90-day global codes like 28525.

06Can 28525 be billed at an ASC?

Yes. CMS assigns 28525 an ASC facility payment distinct from the HOPD rate — see the site-of-service comparison table on this page. The common places of service for this code are 22 (on-campus outpatient hospital) and 24 (ASC).

Sources & references

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

Mira Scribe

Mira's AI scribe captures the specific toe and phalanx fractured, the incision description and approach, whether formal open reduction was performed versus percutaneous access, and the type of internal fixation placed. It also flags when multiple lesser toes are treated so the coder can apply separate digit modifiers (T1–T9) and modifier 51 — preventing the single-MUE denials that hit bundled same-session toe cases most often.

See how Mira captures CPT 28525 documentation