Surgical amputation of the foot performed by transecting through the metatarsal bones, removing all toes and the distal forefoot in a single procedure.

Verified May 8, 2026 · 7 sources ↓

Medicare: $649.31
Work RVU: 12.39
Global, days: 90
Region: Foot & ankle

Drawn from CMSAAPCMdclarityEmednyPodiatrym

Documentation requirements

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

Source · Editorial brief grounded in 7 cited references ↓

Operative note must specify the level of bone transection — document that amputation was performed through the metatarsal shafts, not at a joint or more proximal level
Clearly identify which foot (left or right) with corresponding laterality modifier on the claim
Document the indication — e.g., diabetic foot infection, osteomyelitis, gangrene, ischemia, trauma — linking ICD-10 diagnosis codes to the clinical necessity for amputation at this level
Record the extent of tissue removed and any concurrent procedures (e.g., bone debridement, wound revision) that may support modifier 22 if unusual complexity is warranted
Document failed or contraindicated conservative treatment options to support medical necessity for amputation rather than a more distal procedure
If only a partial transmetatarsal resection was performed (fewer than all five rays), clarify the anatomy in the operative note to defend 28805 selection versus 28810

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 76 Repeat, same 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 7 cited references ↓

28805 covers a transmetatarsal amputation (TMA) — the surgeon cuts across all five metatarsal bones to remove the forefoot, including all toes. This is a single-unit code regardless of how many metatarsals are transected; billing one unit covers the entire transmetatarsal level. Don't stack 28810 (single metatarsal with toe) for each ray — that's a misrepresentation of the procedure and a common audit trigger.

28805 carries a 90-day global period. All routine post-op wound checks, dressing changes, and stump care fall inside that window. Complications requiring a return to the OR during the global period use modifier 78 (related, unplanned) or 79 (unrelated). The procedure requires a hospital inpatient setting — CMS designates 28805 as an inpatient-only procedure (status indicator C under OPPS), so HOPD outpatient and ASC facility billing is not a covered pathway under Medicare.

Indications are typically severe diabetic foot infection, critical limb ischemia with tissue loss, or traumatic forefoot destruction. Laterality modifiers LT or RT are required; bilateral TMA is rare but would use modifier 50. New York State Medicaid explicitly mandates a hospital setting for this code. Always verify payer-specific facility requirements before scheduling in a non-inpatient environment.

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 (12.39) is the surgeon's own effort — the figure physician pay and productivity targets are built on. The total RVU (19.44) adds practice overhead and malpractice, and is what drives the Medicare payment below.

Work RVU	12.39
Practice expense RVU	5.49
Malpractice RVU	1.56
Total RVU	19.44
Medicare national rate	$649.31
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	$649.31
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 28805 get rejected.

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

Billed in an outpatient or ASC facility setting — 28805 is CMS inpatient-only (status C); Medicare will deny HOPD or ASC claims outright
Unbundling with multiple units of 28810 for individual rays — 28805 is one unit covering all metatarsals; stacking per-ray codes triggers NCCI edits
Missing laterality modifier (LT or RT) — payers require site identification and will return the claim or deny without it
Insufficient documentation of medical necessity — operative or pre-op notes that don't link the amputation level to a specific clinical indication (infection extent, vascular status, imaging findings) invite medical necessity denials
Global period violations — billing routine post-op visits or wound care separately within the 90-day global without modifier 24 or 25

Frequently asked questions

Source · Generated from the editorial pipeline, verified against 7 cited references ↓

01Can I bill 28805 once per ray if the surgeon transected three metatarsals?

No. 28805 is one unit regardless of how many metatarsals are cut. It describes a transmetatarsal amputation as a single procedure. Billing multiple units or stacking 28810 per ray is incorrect coding and triggers NCCI edits.

02Is 28805 payable in an outpatient hospital or ASC under Medicare?

No. CMS designates 28805 as an inpatient-only procedure (status indicator C under OPPS). Medicare will not reimburse this code in an HOPD or ASC setting. It must be performed in an inpatient hospital environment.

03What modifier do I use if the patient returns to the OR during the 90-day global for wound dehiscence related to the TMA?

Use modifier 78 — unplanned return to the OR for a procedure related to the original surgery during the global period. Modifier 79 is for unrelated procedures during the global; don't invert them.

04How does 28805 differ from 28810 and 28800?

28800 is a midtarsal (Chopart-level) amputation, more proximal. 28805 is transmetatarsal — across all five metatarsal shafts. 28810 is a single-ray amputation (one metatarsal with its toe). Use 28805 only when the entire forefoot is removed at the metatarsal level.

05Do I need modifier 50 for bilateral transmetatarsal amputation?

Yes. Bilateral TMA on the same operative session is rare but does occur in severe bilateral diabetic or vascular disease. Append modifier 50 and confirm your payer's bilateral payment policy — some require separate line items with LT and RT instead.

06What ICD-10 codes most commonly support medical necessity for 28805?

Common pairings include diabetic foot ulcer with gangrene (E11.52), osteomyelitis of metatarsal bones (M86.x7x), peripheral arterial disease with critical limb ischemia, and traumatic forefoot crush injuries. The ICD-10 must reflect the extent of tissue involvement at the transmetatarsal level.

07Can a podiatrist bill 28805, or is this restricted to orthopedic surgeons?

Both podiatrists and physicians (including orthopedic and vascular surgeons) bill 28805. CMS PUF data shows podiatry as the top billing specialty. Scope-of-practice rules are state-specific; confirm the performing provider's licensure allows amputation at this level in your state.

Sources & references

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

Mira Scribe

Mira's AI scribe captures the amputation level (transmetatarsal, through metatarsal shafts), operative laterality, wound findings, indication (e.g., osteomyelitis, gangrene, ischemia), and any concurrent bone or soft-tissue work from the surgeon's dictation. That specificity prevents the two most common denials: wrong-level code selection and missing medical necessity documentation linking the forefoot loss to the clinical picture.

See how Mira captures CPT 28805 documentation