Survey says: Incision required for foot FBR. Not so fast: Be Safe: Apply Soft-Tissue Incision Rules While the descriptors might appear to "justify the assignment of 28190-28193 if no incision is made, CPT guidelines consider that a non-invasive procedure and will not warrant any additional coding besides the E/M," says Pamela Cline, RHIT, senior coding supervisor for Medical Account Services in Frederick, Md. In short: Another coder who's seen her share of FBRs concurs with Cline's stance on foot FBRs. "Any of the FBR codes in the musculoskeletal chapter [of CPT] involve an incision going beyond the skin level. You need an incision to get that deep," before reporting 28190-28193, says Gerri Walk, RHIA, CCS-P, senior manager at Health Record Services Corporation in Baltimore. Best bet: At the very least, check your payer contract before coding a foot FBR sans incision.