Midtarsal or tarsometatarsal fusion of multiple or transverse joints that includes an osteotomy — such as a metatarsal shaft resection — to correct flatfoot deformity.

Verified May 8, 2026 · 6 sources ↓

Medicare: $728.47
Total RVUs: 21.81
Global, days: 90
Region: Foot & ankle

Drawn from CMSAAPCTldsystemsEmednyGenhealth

Documentation requirements

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

Source · Editorial brief grounded in 6 cited references ↓

Specify that multiple joints were fused — list each joint by name (e.g., first and second tarsometatarsal, naviculocuneiform).
Explicitly document that an osteotomy was performed, including which bone was cut, the type of osteotomy, and the realignment achieved.
Document fixation hardware used (screw size, plate type, rod configuration) and confirm bone apposition.
Record the clinical indication — diagnosis of end-stage midfoot arthritis, flatfoot deformity, or post-traumatic arthropathy — and confirm conservative measures were exhausted.
If bone graft was used, document the graft source, harvest site, and whether a separate incision was required.
Describe wound closure and post-op immobilization plan to support global period billing compliance.

Applicable modifiers

Modifiers commonly billed with this code.

Source · AMA CPT modifier descriptors · CMS NCCI Policy Manual

22 Increased complexity 51 Multiple procedures 59 Distinct service 62 Co-surgeons 78 Unplanned return — related 79 Unrelated during global 80 Assistant surgeon LT Left side RT Right side

What this code covers

Source · Editorial summary grounded in 6 cited references ↓

CPT 28735 covers arthrodesis of multiple midtarsal or tarsometatarsal joints combined with an osteotomy performed at the same surgical setting. The osteotomy component — typically a metatarsal shaft cut and realignment — is what separates this code from 28730 (same joint pattern, no osteotomy) and 28740 (single joint, no osteotomy). The classic indication is end-stage osteoarthritis of the midfoot with structural deformity, such as post-traumatic flatfoot or Lisfranc arthropathy requiring realignment.

The procedure involves cartilage resection from the affected joint surfaces, bone cutting and repositioning via osteotomy, and rigid internal fixation using screws, plates, or rods. Both orthopedic surgeons and podiatric surgeons perform this procedure, typically in an HOPD or ASC setting. The 90-day global period applies — routine post-op visits, dressing changes, and hardware checks through day 90 are not separately billable.

Code selection hinges on two simultaneous criteria: multiple joints fused AND an osteotomy performed. If the operative note documents only one joint fused, bill 28740. If multiple joints are fused without osteotomy, bill 28730. Auditors and MACs look for this distinction, and upcoding from 28740 to 28735 by mischaracterizing single-joint fusions with osteotomy is a documented audit trigger. When bone graft is harvested through a separate incision, 20900 is separately reportable with modifier 59.

RVU & reimbursement

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

Source · CMS Physician Fee Schedule, RVU26A · January 2026

Work RVU	11.92
Practice expense RVU	8.07
Malpractice RVU	1.82
Total RVU	21.81
Medicare national rate	$728.47
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	$728.47
HOPD (APC 5115) Hospital outpatient department	$13,116.76
ASC (PI J8) Ambulatory surgical center (freestanding)	$10,232.44

Common denial reasons

The recurring reasons claims for CPT 28735 get rejected.

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

Upcoding denial: operative note documents only one joint fused, which maps to 28740, not 28735.
Missing osteotomy documentation: multiple joints fused but no osteotomy described, which maps to 28730.
Bundling conflict: 28300 (calcaneal osteotomy) billed same-day without modifier 59 to establish a distinct surgical site.
Laterality omitted: claim submitted without LT or RT modifier, triggering payer edit or rejection.
Global period violation: post-op visit billed without modifier 24 or 25 within the 90-day global window when the visit addressed a related issue.

Frequently asked questions

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

01What is the difference between 28735 and 28730?

Both cover fusion of multiple midtarsal or tarsometatarsal joints. 28735 requires that an osteotomy — such as a metatarsal shaft resection or bone cut for realignment — was also performed. If no osteotomy occurred, bill 28730.

02What is the difference between 28735 and 28740?

28740 is for a single midtarsal or tarsometatarsal joint fusion. 28735 requires multiple joints AND an osteotomy. Billing 28735 for a single-joint fusion with osteotomy is incorrect regardless of osteotomy complexity.

03Can I bill bone graft separately with 28735?

Yes, if the graft is harvested through a separate incision, report 20900 with modifier 59 to indicate a distinct procedural service. Graft placed through the primary surgical field is not separately billable.

04Can 28300 (calcaneal osteotomy) be billed same-day as 28735?

Yes, with modifier 59 on 28300 to establish that the calcaneal osteotomy is a distinct procedure performed on a separate structure within the foot. NCCI edits bundle 28300 as a Column 2 code to the arthrodesis without a modifier.

05What global period applies to 28735, and what does it include?

28735 carries a 90-day global period. That covers the day-before preoperative visit, the procedure itself, and all routine post-op care through day 90 — including office visits related to the fusion, dressing changes, and hardware checks. Unrelated services in that window require modifier 24 or 25.

06Should I use modifier 50 or LT/RT for bilateral midfoot fusions?

Simultaneous bilateral fusions are extremely rare for this code. If it occurs, modifier 50 is appropriate. For unilateral procedures — the typical scenario — use LT or RT. Many payers require laterality on foot procedure claims regardless of whether 50 is used.

07Is 28735 appropriate for Lisfranc post-traumatic arthritis?

Yes, post-traumatic arthritis following Lisfranc injury is a recognized indication when multiple tarsometatarsal joints are involved and an osteotomy is performed for realignment. Document the prior injury, arthritis progression, and the joints treated.

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 number and names of joints fused, the osteotomy type and bone involved, fixation hardware details, and graft source from dictation — the exact elements that distinguish 28735 from 28730 and 28740. That prevents the most common audit flag for this code: an operative note that supports a lower-level fusion code while the claim bills 28735.

See how Mira captures CPT 28735 documentation