Arthrodesis of the midtarsal or tarsal navicular-cuneiform joint combined with tibialis posterior tendon lengthening and advancement — the Miller-type flatfoot correction procedure.

Verified May 8, 2026 · 6 sources ↓

Medicare: $631.95
Work RVU: 10.75
Global, days: 90
Region: Foot & ankle

Drawn from CMSAAPCEmednyFacsHhs

Documentation requirements

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

Source · Editorial brief grounded in 6 cited references ↓

Specify which joints were fused — navicular-cuneiform, midtarsal, or both — by name in the operative note.
Document the type and location of fixation hardware used (screws, K-wires, plates) and confirm bone apposition.
Describe the tibialis posterior tendon lengthening technique and the advancement attachment point explicitly; this tendon work differentiates 28737 from 28730/28735.
State the indication — typically adult-acquired or pediatric flatfoot deformity with tibialis posterior dysfunction — with supporting imaging referenced.
Document pre-operative weight-bearing radiographs confirming deformity and failed conservative management if required by payer.
Identify laterality (left vs. right) in both the operative note and on the claim.

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 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 28737 describes surgical fusion of the midtarsal or navicular-cuneiform joint accompanied by lengthening and advancement of the tibialis posterior tendon — the construct commonly called the Miller procedure. The navicular and cuneiform bones are immobilized using internal fixation (screws, K-wires, or plates), and the tibialis posterior tendon is simultaneously lengthened and advanced to correct the deforming force driving the flatfoot deformity. This is not a simple midtarsal fusion; the tendon work is intrinsic to the code, not an add-on.

The 90-day global period covers the operative day, the day-before visit, and all routine post-op care through day 90 — including cast changes, suture removal, and routine wound checks. Anything unrelated to the flatfoot correction in that window requires modifier 24 or 25. Per the 2023 ACS/specialty consensus, a physician assistant at surgery is appropriate 'sometimes,' so modifier 80 is defensible when documented — but payers vary on whether they'll pay it without prior authorization.

Bundling questions arise frequently when 28737 is performed alongside a triple arthrodesis (28715). These are not automatically bundled, but payers and NCCI edits govern whether both are separately payable at the same session — always check current NCCI edits and attach modifier 59 with solid operative note support if billing both.

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 (10.75) is the surgeon's own effort — the figure physician pay and productivity targets are built on. The total RVU (18.92) adds practice overhead and malpractice, and is what drives the Medicare payment below.

Work RVU	10.75
Practice expense RVU	6.83
Malpractice RVU	1.34
Total RVU	18.92
Medicare national rate	$631.95
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	$631.95
HOPD (APC 5115) Hospital outpatient department	$13,116.76
ASC (PI J8) Ambulatory surgical center (freestanding)	$9,646.35

Common denial reasons

The recurring reasons claims for CPT 28737 get rejected.

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

Missing tendon work documentation — payers downcode to 28730 or 28735 when the operative note doesn't explicitly describe tibialis posterior lengthening and advancement.
Laterality not specified on the claim, causing claim rejection or suspended adjudication.
Bundling conflict when 28737 is billed same-session with 28715 (triple arthrodesis) without modifier 59 and distinct operative note support.
Medical necessity denial when pre-operative conservative treatment trial is not documented or imaging is absent from the record.
Global period violation — post-op E/M visits billed without modifier 24 when unrelated to the foot fusion are denied as included in the 90-day global.

Frequently asked questions

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

01What separates 28737 from 28730 and 28735?

28730 is a plain midtarsal or tarsometatarsal fusion. 28735 adds an osteotomy for flatfoot correction. 28737 specifically requires both the navicular-cuneiform or midtarsal fusion AND tibialis posterior tendon lengthening with advancement. If the tendon work isn't done and documented, you're in 28730 or 28735 territory.

02Can 28737 be billed bilaterally in one session?

Bilateral same-session procedures can be reported with modifier 50 on a single line or on separate lines with LT and RT. Expect most payers to apply a 50% reduction to the second side. Confirm bilateral medical necessity is documented — symptomatic bilateral flatfoot deformity with tibialis posterior dysfunction on both sides.

03If I also perform a triple arthrodesis (28715) at the same session, do I bill both?

28737 and 28715 are not automatically bundled, but current NCCI edits and individual payer policies govern separate payment. If both are genuinely performed and documented as distinct procedures, append modifier 59 to the lower-value code. The operative note must clearly describe each procedure as separate and necessary — do not assume automatic payment.

04Is a physician assistant at surgery billable for 28737?

The 2023 ACS assistant-at-surgery consensus lists 28737 as 'sometimes' requiring a physician assistant. That means modifier 80 is defensible when the complexity warrants it and is documented, but it's not presumptively payable. Some payers require prior authorization; Medicare allows modifier 80 only when not restricted by their assistant-at-surgery payment policy.

05What ICD-10 diagnoses are most commonly paired with 28737?

Adult-acquired flatfoot deformity (M21.4x) and tibialis posterior tendon dysfunction staging codes are the most clinically consistent diagnoses. Pediatric flexible flatfoot (Q66.5x) is used for pediatric cases. The diagnosis must match the documented deformity and justify both the fusion and the tendon procedure.

06Does the 90-day global include cast management and hardware-related follow-up?

Yes. All routine post-op visits, cast changes, suture removal, and standard wound checks within 90 days are bundled into the global. Hardware-related complications requiring a return to the OR are reported with modifier 78 (related, unplanned) or 79 (unrelated). A new, unrelated E/M during the global needs modifier 24.

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 joints fused (navicular-cuneiform, midtarsal), fixation hardware type and placement, and the tibialis posterior tendon lengthening and advancement technique directly from dictation. It flags operative notes that describe only 'midtarsal fusion' without tendon detail — the single most common reason 28737 is downcoded to 28730 on audit.

See how Mira captures CPT 28737 documentation