E11.621
BillableType 2 diabetes mellitus with foot ulcer
Last updated: FY2026 ICD-10-CM (Oct 1, 2025 – Sep 30, 2026) | CMS-HCC V28 (100% phase-in, PY2026)
Is E11.621 an HCC code?
No. E11.621 is a billable ICD-10-CM code but does not map to any HCC category in V28, V24, ESRD, or RxHCC.
This code does not map to an HCC category in any model (V28, V24, ESRD, RxHCC).
What This Code Means
E11.621 is the ICD-10-CM diagnosis code for type 2 diabetes mellitus with foot ulcer. Type 2 diabetes resulting in an open sore or wound on the foot that fails to heal properly. E11.621 sits in the ICD-10-CM chapter for endocrine, nutritional and metabolic diseases (e00-e89), within the section covering diabetes mellitus (e08-e13).
E11.621 is a billable ICD-10-CM code but does not map to a payment HCC under the CMS-HCC V28, V24, ESRD, or RxHCC risk adjustment models. It can be reported on Medicare Advantage encounter data submissions but it does not contribute to a beneficiary's RAF score and therefore does not affect risk-adjusted payments to the plan.
Does not map to any HCC in V28, V24, ESRD, or RxHCC models. This is a critical risk adjustment gap for a high-resource condition. Ensure all concurrent complications (neuropathy, peripheral vascular disease, infection) are captured separately, as these may map to HCCs and better reflect the patient's true disease burden.
HCC Buddy maintains structured V28 and V24 mapping, RAF weights, and MEAT documentation criteria for E11.621 sourced directly from the CMS-HCC risk adjustment model files and the CMS ICD-10-CM code set.
Coding Tips
- •Always specify the location and severity of the foot ulcer using additional codes if available
- •Document whether the ulcer is infected, as this affects treatment and coding specificity
Clinical Significance
Type 2 diabetes mellitus with foot ulcer is one of the most clinically significant diabetic complications, representing the primary pathway to non-traumatic lower extremity amputation. Diabetic foot ulcers develop from the convergence of peripheral neuropathy (loss of protective sensation), peripheral arterial disease (impaired blood flow), and foot deformity (abnormal pressure distribution). Annual incidence in diabetic patients is 2-5%, with lifetime risk as high as 25%.
Documentation Requirements
- ✓Documentation must specify a foot ulcer in a Type 2 diabetic patient, including precise anatomical location (heel, midfoot, forefoot, toe), ulcer dimensions, depth classification (Wagner grade or University of Texas classification), and presence of infection or exposed structures.
- ✓An additional L97 code must be assigned for ulcer site and severity specificity.
- ✓Vascular assessment, neuropathy evaluation, and wound care plan should be documented.
Commonly Confused Codes
- •E11.622 (other skin ulcer) is for non-pedal ulcer locations.
- •E11.52 (peripheral angiopathy with gangrene) indicates tissue death beyond ulceration.
- •L97.4-L97.5 (non-pressure chronic ulcer of foot) are required additional codes for site specificity.
- •E11.620 (diabetic dermatitis) covers inflammatory skin conditions without ulceration.