According to Coding Companion 2009 by Ingenix Ortho-lower hips and below page 438:
"In 28510, separately reportable x-rays of the toe confirm a fracture or fractures of the bones where the fragments are in an acceptable position. The physician applies a splint, brace, or cast to the toe and foot."
This procedure may be reported multiple times as it is reported for each closed treatment of a phalangeal fracture performed.
I take this to mean that there must be some treatment, other than buddy taping required. (cast, splint, or brace)
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