C25.9 ICD-10-CM Code: Malignant neoplasm of pancreas, unspecified
HCC Buddy Code Card
Digital ICD-10 code-book layout with official code detail, always-visible risk models, Code Trumping, and Buddy coding guidance.
FY 2026 Apr update / Neoplasms (C00-D49) / Malignant neoplasms of digestive organs (C15-C26)
C25.9
Billable / SpecificICD-10-CMOfficial ICD-10-CMCodebook guidanceMalignant neoplasm of pancreas, unspecified
Pancreatic cancer where the exact location within the pancreas has not been specified or determined.

Buddy Insight
Unspecified pancreatic cancer is used when documentation confirms malignancy but lacks anatomical specificity.
CMS-HCC V28
MappedHCC 20
RAF 0.0
CMS-HCC V24
MappedHCC 9
RAF 0.973
ACA/HHS
00
RAF 0
ESRD/PACE
MappedHCC 9
RAF 0.0
RXHCC
MappedHCC 20
RAF 0.0
Code Trumping
Basket needed
Code Book Path
Inclusion Terms
OfficialICD-10-CM does not list inclusion terms for C25.9 in this effective period.
Excludes 2
OfficialICD-10-CM does not list Excludes 2 notes for C25.9 in this effective period.
Related Child Codes
Includes
OfficialICD-10-CM does not list Includes notes for C25.9 in this effective period.
Excludes 1
OfficialICD-10-CM does not list Excludes 1 notes for C25.9 in this effective period.
Code First
OfficialICD-10-CM does not list Code First sequencing instructions for C25.9 in this effective period.
Use Additional
Official- code to identify:
- alcohol abuse and dependence (F10.-)
Code Also
Official- if applicable exocrine pancreatic insufficiency (K86.81)
Buddy Documentation Tip
MEAT Support
Audit Caution
Common Mistakes
Last updated: FY2026 ICD-10-CM Apr update, Apr 1, 2026 through Sep 30, 2026. CMS-HCC V28 is 100% phased in for payment year 2026.
Is C25.9 an HCC code?
Yes. C25.9 maps to Lung and Other Severe Cancers under the CMS-HCC V28 risk adjustment model (and Lung and Other Severe Cancers under V24).
HCC Category Mapping
RAF weights shown are the community, non-dual, aged base weights from the CMS risk adjustment model file. Actual per-patient RAF contribution depends on member segment, interactions, and the model year used by the payer. V28 is the CMS-HCC model phased in over payment years 2024–2026; V24 remains in use during the transition and for historical data.
MEAT Criteria for C25.9
For C25.9to count as a valid HCC diagnosis in a given encounter, the provider's documentation must show MEAT: Monitor, Evaluate, Assess, or Treat. A diagnosis from a prior year does not carry forward automatically, it has to be re-documented and supported each calendar year.
- MMonitor: signs, symptoms, disease progression, or lab trending documented in the note
- EEvaluate: test results, medication response, or physical findings reviewed by the provider
- AAssess: explicit mention in the assessment or plan with acknowledgment of status
- TTreat: medication, referral, procedure, therapy, or counseling tied to the diagnosis
Only one of M/E/A/T is required to support the code, but the documentation must be specific enough to show that the provider actually addressed C25.9 during that encounter, not just copy-forwarded from a problem list.
What This Code Means
C25.9 is the ICD-10-CM diagnosis code for malignant neoplasm of pancreas, unspecified. Pancreatic cancer where the exact location within the pancreas has not been specified or determined. C25.9 sits in the ICD-10-CM chapter for neoplasms (c00-d49), within the section covering malignant neoplasms of digestive organs (c15-c26).
Under the CMS-HCC V28 risk adjustment model, C25.9 maps to Lung and Other Severe Cancers (HCC 20) with a community, non-dual, aged base RAF weight of 0.000. Under the older V24 model, C25.9 mapped to the same category but with a base RAF weight of 0.973, V28 recalibrated weights across the entire model. V28 is the CMS-HCC risk adjustment model that reached 100% phase-in for payment year 2026, replacing V24 which was used during the PY2024–PY2025 transition.
This is a less specific code; use only when the exact pancreatic site cannot be determined from documentation. Because C25.9 maps to a payment HCC, the provider's documentation must satisfy MEAT criteria (Monitor, Evaluate, Assess, or Treat) for the encounter to count toward the patient's Medicare Advantage risk adjustment score. When documentation is ambiguous, coders should issue a provider query rather than assume the highest-specificity variant.
HCC Buddy maintains structured V28 and V24 mapping, RAF weights, and MEAT documentation criteria for C25.9 sourced directly from the CMS-HCC risk adjustment model files and the CMS ICD-10-CM code set.
Coding Tips
- •This is a less specific code; use only when the exact pancreatic site cannot be determined from documentation
- •Query the provider if more specific location information is available to allow for more precise coding
Clinical Significance
Unspecified pancreatic cancer is used when documentation confirms malignancy but lacks anatomical specificity. Pancreatic cancer carries one of the highest mortality rates among solid tumors, making it critical for risk adjustment. However, this unspecified code may trigger audit scrutiny — providers should be queried for greater specificity whenever possible.
Documentation Requirements
- ✓Pathology or clinical confirmation of pancreatic malignancy
- ✓Evidence that more specific site information is not available after provider query
- ✓Current treatment status (active treatment, surveillance, hospice)
- ✓Stage if known
- ✓Documentation explaining why specific site cannot be determined
Commonly Confused Codes
- •C25.0 — Head of pancreas: Most pancreatic cancers arise in the head — review imaging and surgical notes before defaulting to C25.9
- •C25.1 — Body of pancreas and C25.2 — Tail of pancreas: Review all available records for anatomical detail
- •Z85.07 — Personal history of malignant neoplasm of pancreas: Use when cancer is no longer active and treatment is complete
- •D13.6 — Benign neoplasm of pancreas: Ensure malignancy is confirmed before coding any C25 code