Surgical amputation of the foot at the midtarsal (transverse tarsal) joint level, disarticulating through the talonavicular and calcaneocuboid joints, removing the forefoot while preserving the hindfoot.

Verified May 8, 2026 · 6 sources ↓

Medicare: $491.33
Work RVU: 8.57
Global, days: 90
Region: Foot & ankle

Drawn from AAPCMdclarityCMSCgsmedicare

Documentation requirements

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

Source · Editorial brief grounded in 6 cited references ↓

Operative note must explicitly name the joint level of amputation — talonavicular and calcaneocuboid — not just 'midfoot level'
Identify specific indication (e.g., diabetic gangrene, trauma, vascular insufficiency, osteomyelitis) with supporting diagnosis codes
Document extent of tissue removed and any flap creation or closure technique used for stump formation
Record laterality (left or right foot) clearly in the operative note and on the claim
If tendon transfers or additional procedures were performed concurrently, document medical necessity for each separately
Pre-operative imaging or vascular studies supporting amputation level decision should be referenced in the operative note

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 50 Bilateral procedure 52 Reduced services 58 Staged or related 59 Distinct service 74 Discontinued post-anesthesia 76 Repeat, same physician 77 Repeat, another physician 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 28800 describes amputation of the foot at the midtarsal joints — specifically the talonavicular and calcaneocuboid joints — leaving the calcaneus and talus intact. This level of amputation is distinct from a more distal Lisfranc-level amputation (28805), which transects through the tarsometatarsal joints. Choosing between 28800 and 28805 depends entirely on the documented joint level of disarticulation; operative notes that describe the level ambiguously are a primary audit and denial trigger.

The procedure carries a 90-day global period. All routine post-operative care — wound checks, dressing changes, suture removal, stump management visits — is bundled from the day before surgery through day 90. Unrelated E/M services within the global window require modifier 24; a separately identifiable same-day E/M requires modifier 25 appended to that visit. Tendon transfer codes (e.g., 27690, 27692) billed same-day are subject to NCCI bundling review and have generated documented Medicare denials.

This code is performed in both HOPD and ASC settings. Site of service affects facility payment only — see the Site of Service comparison table for current figures. Laterality modifiers (LT/RT) are required by most payers for unilateral procedures on paired anatomical structures, and 28800 should be reported with the appropriate modifier when performed on a single foot.

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 (8.57) is the surgeon's own effort — the figure physician pay and productivity targets are built on. The total RVU (14.71) adds practice overhead and malpractice, and is what drives the Medicare payment below.

Work RVU	8.57
Practice expense RVU	5.12
Malpractice RVU	1.02
Total RVU	14.71
Medicare national rate	$491.33
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	$491.33
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 28800 get rejected.

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

Wrong code selected — 28800 vs. 28805 confusion when the operative note doesn't specify the exact joint of disarticulation
NCCI bundling denial when tendon transfer codes (27690, 27692) are billed same-day without a clinically supported modifier 59
Missing or incorrect laterality modifier — most payers require LT or RT for foot procedures
Unrelated or routine post-op E/M visits billed within the 90-day global without modifier 24
ICD-10 diagnosis code doesn't support the amputation level or doesn't match the site documented in the operative note

Frequently asked questions

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

01What's the difference between CPT 28800 and 28805?

28800 is disarticulation at the midtarsal (talonavicular/calcaneocuboid) joints, preserving the entire hindfoot. 28805 is amputation through the transmetatarsal area — a more distal level through the metatarsal shafts. The operative note must name the joint level to support whichever code you bill.

02Can I bill tendon transfers on the same day as 28800?

Medicare has denied this combination. Codes 27690 and 27692 billed same-day with 28800 trigger NCCI bundling edits. If the tendon transfer is truly a separate, clinically distinct service, modifier 59 (or XS) is required and the medical record must support the separate necessity — but expect scrutiny.

03Do I need a laterality modifier on 28800?

Yes. Most payers, including Medicare, require LT or RT on foot surgery claims. Missing laterality is a straightforward edit that delays or denies payment. Bill 28800-LT or 28800-RT as appropriate.

04What does the 90-day global period cover for 28800?

The global covers the day-before visit, the surgery, and all routine post-op care through day 90 — wound checks, dressing changes, suture removal, and stump management. Bill modifier 24 on unrelated E/M visits in that window, or modifier 78 if an unplanned return to the OR is needed for a related complication.

05What ICD-10 codes are typically linked to 28800?

The most common indications are diabetic foot gangrene (E11.52, E10.52), peripheral vascular disease with gangrene (I70.261–I70.269), osteomyelitis of the foot (M86.371–M86.379), and traumatic tissue loss. The diagnosis must match the documented amputation level and site — a mismatch between the code and the operative note is a top audit flag.

06Can 28800 be performed in an ASC?

Yes. 28800 is payable in both HOPD and ASC settings. The facility payment differs between the two — see the Site of Service comparison table for current 2026 figures. The physician's professional fee is the same regardless of setting.

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 named joint level of disarticulation (talonavicular, calcaneocuboid), documented laterality, the clinical indication driving amputation level selection, and any concurrent procedures performed. This prevents the most common 28800 denial — an operative note that says 'midfoot amputation' without specifying the exact joint, which auditors flag as insufficient to distinguish 28800 from 28805.

See how Mira captures CPT 28800 documentation