Condition guide
Diabetes Mellitus (Type 2) HCC Coding Guide
Diabetes Mellitus (Type 2) (e.g. E11.22) maps to HCC 37 (Diabetes with Chronic Complications) under the CMS-HCC V28 risk adjustment model, with a community, non-dual, aged RAF weight of 0.166; V28 reached 100% phase-in for payment year 2026. It can also map to HCC 383 (Chronic Ulcer of Skin, Except Pressure, Not Specified as Through to Bone or Muscle) and HCC 298 (Severe Diabetic Eye Disease, Retinal Vein Occlusion, and Vitreous Hemorrhage) when the documentation supports those manifestations.
Quick Facts
HCC Categories
HCC 383, Chronic Ulcer of Skin, Except Pressure, Not Specified as Through to Bone or Muscle
HCC 298, Severe Diabetic Eye Disease, Retinal Vein Occlusion, and Vitreous Hemorrhage
HCC 38, Diabetes with No, Glycemic, or Unspecified Complications
HCC 37, Diabetes with Chronic Complications
RAF Weight Range
0.166 to 0.646
Community, non-dual, aged (V28)
Model
CMS-HCC V28 (PY2026, 100% phase-in)
10 ICD-10 codes map to payment HCCs
Video lesson
The Diabetes Code That Pays Twice (2026 HCC Deep Dive)
A deep dive on coding diabetes under V28: the five code families, the assumed “with” link, the uncontrolled-vs-poorly-controlled trap, E11.22's required N18 stage, and E11.621 — the one code that opens two HCCs (37 and 383).
Key takeaways
- Diabetes has five code families — E08 (underlying condition), E09 (drug/chemical induced), E10 (type 1), E11 (type 2), E13 (other specified). The family determines every code after it.
- Everything indented under “diabetes, with” in the alphabetic index is assumed to be caused by the diabetes — kidney disease, neuropathy, retinopathy, foot ulcers — no explicit provider link needed unless the provider states another cause.
- “Uncontrolled” is a question, not a code: it forks to hyperglycemia (E11.65) or hypoglycemia (E11.649) with no default — query the provider. “Poorly controlled”, “out of control”, and “inadequately controlled” do index to E11.65.
- E11.621 (type 2 diabetes with foot ulcer) pays two HCCs: HCC 37 (0.166) plus HCC 383 chronic skin ulcer (0.646) with the L97 site code — the ulcer is worth almost four times the diabetes.
- E11.22 carries a “use additional code” instruction: add the CKD stage (N18.1–N18.6, or N18.9 if unstaged). Add Z79.4 (insulin) or Z79.84 (non-insulin drugs) for type 2 — never the insulin code for type 1.
- V28 flattened the diabetes tiers to one 0.166 weight, so the value now lives in the second HCC a real complication opens.
Read the full transcript
Diabetes is the condition you will code more than any other, and the one that gets under coded more than any other. It hides in plain sight on the problem list, and a lazy code leaves money and accuracy on the table. So let's really get into it. Meet Rosa. She has a stack of diabetes charts and thirty minutes. Let me show you how she codes every one of them right.
First, get the family right. Diabetes is not one code, it is five doorways. E11 is type 2, the one you'll see most. E10 is type 1. E08 is diabetes due to an underlying condition. E09 is drug or chemical induced. E13 is other specified. Walk through the wrong door and every code after it is wrong.
Now the single most important rule in diabetes coding: the word with. In the alphabetic index, everything indented under diabetes with is assumed to be caused by the diabetes. Kidney disease, neuropathy, retinopathy, a foot ulcer. You code the combination, and you do not need the provider to spell out the link. The link is assumed, unless the provider says it is something else.
Start at the floor. Type 2 diabetes with no complications is E11.9. It maps to HCC 38, worth 0.166. That is the baseline every diabetic patient earns just for being documented and managed this year. But almost nobody with real diabetes stays at the floor, so let's climb.
Here is the trap that catches everyone. The note says diabetes, uncontrolled, and your hand reaches for E11.65, hyperglycemia. Stop. In the index, uncontrolled does not give you a code. It forks. Meaning high sugar goes to hyperglycemia, E11.65. Meaning low sugar goes to hypoglycemia, E11.649. There is no default, so you query the provider. The words that do earn E11.65 on their own are poorly controlled, out of control, and inadequately controlled. So keep them apart. Uncontrolled is a question. Poorly controlled is a code.
Now we climb. The chart supports diabetic chronic kidney disease, E11.22, and it lands in HCC 37, diabetes with chronic complications. But you are not done. E11.22 carries a use additional code instruction: add the CKD stage. If the provider named the stage, that is N18.1 through N18.6. If the chart says diabetic kidney disease but never names the stage, do not guess. You use N18.9, chronic kidney disease unspecified. Either way, an N18 code has to be there, or the chart is incomplete.
Here is where coders leave the most money on the table. Diabetes with a foot ulcer, E11.621. It lands in HCC 37 like the kidney disease did. But the ulcer opens a second door: HCC 383, chronic skin ulcer, worth 0.646. That one code pays two HCCs, and the ulcer is worth almost four times the diabetes. Miss the second HCC and you have under coded this chart badly.
This is the mind shift V28 forces. The model flattened diabetes: with complications or without, the diabetes itself now pays the same 0.166. So the value is not in the diabetes tier anymore. The value is in the second HCC that a real complication opens: the ulcer, the kidney stage, the vascular disease. Code the diabetes, then chase what it brought with it.
Don't forget the medicines. If a type 2 patient is on long term insulin, add Z79.4. If they are on a long term non-insulin drug, like metformin, add Z79.84. These are quick code-also companions that support the picture. One exception: never add the insulin code for a type 1 patient. Type 1 is insulin dependent by definition, so the code would be redundant.
Let's name the conditions coders miss, because these are the ones that fall off charts every day. One: the second HCC on a complication, the ulcer or vascular code. Two: the CKD stage that E11.22 demands. Three: neuropathy, retinopathy, and peripheral vascular disease that the provider documented separately but nobody linked back to the diabetes under with. Four: defaulting to E11.9 when the chart clearly supports more.
Now the other side: when NOT to code. Diabetes is chronic, so history of diabetes is not resolved. It is still current, so keep coding it every year. If the diabetes is drug or chemical induced, it is E09, not E11. And you never stack two diabetes HCCs on one patient. The hierarchy keeps only the highest. Code what the chart supports, and let the rules do the rest.
One combination worth memorizing, because the model pays extra for it. When a patient carries both a diabetes HCC and a heart failure HCC, V28 adds an interaction bonus, 0.112, automatically. Diabetes and a tired heart together are harder to manage than either alone, and the model knows it. You don't code anything extra. It just fires.
One more doorway, so you don't walk through the wrong one. If your patient is pregnant, diabetes leaves chapter four entirely. Pre-existing type 2 diabetes in pregnancy is not E11, it is O24.1. Gestational diabetes, the kind that starts during pregnancy, is O24.4. We have a whole deep dive coming on obstetrics, but remember the rule: pregnant changes the code.
You do not have to hold all of this in your head. Every diabetes code has a page on our site that shows its HCC mapping in both models, the use additional codes it needs, and the weight, side by side. Pull up hccbuddy.com/icd10/E11.9, or any code, and it lays the whole picture out for you.
So that's diabetes, coded right. Get the type. Honor the word with, and let the index assume the link. Add the use additional codes, the kidney stage, the ulcer site. Chase the second HCC, because that is where the value moved. And never, ever settle for unspecified when the chart gives you more. Rosa just cleared her stack. Your turn.
How coders write it
Chart notes, problem lists, and queries rarely spell out Diabetes Mellitus (Type 2). The shorthand you will actually see:
Whatever the note calls it, the payment question is the same: how the ICD-10-CM code resolves to a payment HCC.
What HCC category does Diabetes Mellitus (Type 2) map to under V28?
Type 2 diabetes mellitus is one of the highest-impact conditions in HCC risk adjustment, affecting over 37 million Americans. Under the CMS-HCC V28 model, the E11 codes split into two diabetes categories: uncomplicated, glycemic, or unspecified diabetes maps to HCC 38, while diabetes with chronic complications maps to HCC 37. A key point coders miss is that some E11 combination codes trigger a second payment category on top of the diabetes HCC. A diabetic foot ulcer (E11.621) maps to both HCC 37 and HCC 383 (Chronic Ulcer of Skin), and unspecified diabetic retinopathy with macular edema (E11.311) maps to both HCC 37 and HCC 298 (Severe Diabetic Eye Disease, Retinal Vein Occlusion, and Vitreous Hemorrhage). Neither pair sits in the same hierarchy, so both categories pay. Accurate coding means documenting the diabetes type, the causal link to each manifestation, and the treatment plan so each code lands in its correct HCC.
ICD-10 to HCC Mapping
| ICD-10 Code | Description | Billable | HCC Mapping |
|---|---|---|---|
| E11.9 | Type 2 diabetes mellitus without complications | Yes | HCC 38 |
| E11.65 | Type 2 diabetes mellitus with hyperglycemia | Yes | HCC 38 |
| E11.22 | Type 2 diabetes mellitus with diabetic chronic kidney disease | Yes | HCC 37 |
| E11.40 | Type 2 diabetes mellitus with diabetic neuropathy, unspecified | Yes | HCC 37 |
| E11.311 | Type 2 diabetes mellitus with unspecified diabetic retinopathy with macular edema | Yes | HCC 37 + HCC 298 |
| E11.51 | Type 2 diabetes mellitus with diabetic peripheral angiopathy without gangrene | Yes | HCC 37 |
| E11.621 | Type 2 diabetes mellitus with foot ulcer | Yes | HCC 37 + HCC 383 |
| E11.69 | Type 2 diabetes mellitus with other specified complication | Yes | HCC 37 |
| E11.21 | Type 2 diabetes mellitus with diabetic nephropathy | Yes | HCC 37 |
| E11.42 | Type 2 diabetes mellitus with diabetic polyneuropathy | Yes | HCC 37 |
RAF weights are community, non-dual, aged base coefficients from the CMS-HCC V28 model (PY2026). Verify against the latest CMS rate announcement for payment calculations.
HCC Buddy maps Diabetes Mellitus (Type 2) from the CMS-HCC risk adjustment model files and the CMS ICD-10-CM code set.
Coder workflow notes
Get the V28 RAF + MEAT cheat sheet
A printable one-pager: which Diabetes Mellitus (Type 2) codes risk-adjust under V28, their RAF weights, and the MEAT your notes need. Free, no card.
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Documentation Tips
Always document the specific type of diabetes (Type 1, Type 2, or secondary), never code 'unspecified diabetes' when the type is known.
Document causal relationships between diabetes and complications (e.g., 'diabetic nephropathy' vs. 'nephropathy in a patient with diabetes').
Use combination codes from E11 for diabetes with complications rather than coding diabetes and complications separately.
Specify laterality for diabetic retinopathy and severity of macular edema when applicable.
Document current HbA1c level and whether hyperglycemia or hypoglycemia is present at the encounter.
Record all active diabetic complications at every encounter, do not rely on problem list carry-forward without provider attestation.
Document the treatment plan including medications, insulin use, and monitoring frequency to satisfy MEAT criteria.
MEAT documentation examples for Diabetes Mellitus (Type 2)
A diagnosis only counts toward risk adjustment when the encounter note shows the provider engaged with it. These are the kinds of entries that satisfy the MEAT documentation standard for Diabetes Mellitus (Type 2):
MMonitor
“A1c 8.2 percent today, up from 7.4 percent in March; continue quarterly labs.”
“CGM download reviewed: time in range 58 percent, two overnight lows this month.”
“Urine albumin-creatinine ratio 210 mg/g; repeat in three months.”
EEvaluate
“Monofilament exam: sensation absent at bilateral great toes, vibratory sense diminished.”
“Foot exam: 0.4 cm shallow ulcer, left plantar surface, no surrounding cellulitis.”
“Dilated retinal exam reviewed: moderate NPDR with macular edema, right eye.”
AAssess
“Type 2 diabetes with diabetic polyneuropathy, worsening despite gabapentin.”
“T2DM with stage 3a diabetic CKD, stable; A1c above goal.”
“Uncontrolled T2DM with hyperglycemia; adherence barriers discussed.”
TTreat
“Increase metformin to 1000 mg twice daily; recheck A1c in three months.”
“Started empagliflozin 10 mg daily for renal protection.”
“Referred to podiatry for ulcer debridement; wound care instructions given.”
Common Coding Mistakes
Coding E11.9 (without complications) when the patient has documented diabetic complications, always code to the highest specificity.
Failing to link diabetes as the cause of kidney disease, neuropathy, or retinopathy when the provider has documented the causal relationship.
Using unspecified diabetes codes (E13.x) instead of Type 2 (E11.x) when the type is clearly documented.
Missing the opportunity to code diabetic chronic kidney disease (E11.22) alongside the specific CKD stage code.
Not capturing hyperglycemia (E11.65) when the encounter note documents elevated blood glucose or uncontrolled diabetes.
V24 to V28 Changes
V28 reorganized the diabetes hierarchy into HCC 37 (Diabetes with Chronic Complications) and HCC 38 (Diabetes with No, Glycemic, or Unspecified Complications). Both currently carry the same community RAF of 0.166, so unlike V24, where HCC 18 paid 0.302 against 0.105 for uncomplicated HCC 19, V28 does not reward a complicated diabetes code over an uncomplicated one at the diabetes category alone. The bigger lesson is that some combination codes land in two payment categories at once: E11.621 (foot ulcer) maps to HCC 37 and HCC 383 (RAF 0.646), and E11.311 (retinopathy with macular edema) maps to HCC 37 and HCC 298 (RAF 0.336). Neither pairing shares a hierarchy, so both categories count. Capture each documented manifestation with the specific combination code, not just the base diabetes code.
| Aspect | V24 (through PY2025) | V28 (PY2026) |
|---|---|---|
| Uncomplicated Type 2 (E11.9) | HCC 19, Diabetes without Complication, RAF 0.105 | HCC 38, Diabetes with No, Glycemic, or Unspecified Complications, RAF 0.166 |
| Chronic complications (E11.22, E11.40, E11.42) | HCC 18, Diabetes with Chronic Complications, RAF 0.302 | HCC 37, Diabetes with Chronic Complications, RAF 0.166 |
| Hyperglycemia (E11.65) | Treated as a complication under HCC 18, RAF 0.302 | Grouped with uncomplicated diabetes under HCC 38, RAF 0.166 |
| Complicated vs. uncomplicated payment gap | Complications nearly tripled the diabetes weight | No gap; both diabetes categories pay the same |
| Diabetic foot ulcer (E11.621) | HCC 18 plus the V24 ulcer category HCC 161 | HCC 37 plus HCC 383, RAF 0.646; both categories pay |
RAF values are community, non-dual, aged base coefficients for each model's payment year. To see what these weights do to a real patient total, run the codes through the RAF score calculator.
Diabetes Mellitus (Type 2) coding FAQs
Does E11.9 still risk-adjust under V28?
Yes. E11.9 (Type 2 diabetes without complications) maps to HCC 38 with a community, non-dual, aged RAF weight of 0.166 under CMS-HCC V28. What changed is the payoff for complications: V24 paid 0.302 for complicated diabetes against 0.105 for uncomplicated, while V28 pays 0.166 for both HCC 37 and HCC 38. Complications still matter for the hierarchy and for manifestation categories like HCC 383, just not for the base diabetes weight.
What is the difference between HCC 37 and HCC 38?
HCC 37 is Diabetes with Chronic Complications and HCC 38 is Diabetes with No, Glycemic, or Unspecified Complications. HCC 37 sits above HCC 38 in the V28 hierarchy, so a patient with both a complicated and an uncomplicated diabetes code gets credit for HCC 37 only. Both carry a community, non-dual, aged RAF weight of 0.166 for payment year 2026.
Why does E11.65 map to HCC 38 instead of HCC 37?
V28 treats hyperglycemia as a glycemic status rather than a chronic complication, so E11.65 groups with uncomplicated and unspecified diabetes in HCC 38. Under V24 the same code counted as a complication and paid the higher HCC 18 weight, which is why coders moving from V24 keep expecting it in the complicated category.
Related Conditions
Related references
Sources
RAF weights are community, non-dual, aged base coefficients from the CMS-HCC V28 model (PY2026). Verify against the latest CMS Rate Announcement for payment.
Verified current to CMS-HCC V28, payment year 2026 — last reviewed July 16, 2026.
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