E11.621 vs E11.622
E11.621 (Type 2 diabetes mellitus with foot ulcer) compared with E11.622 (Type 2 diabetes mellitus with other skin ulcer), from the official CMS tabular data.
Current data releases:ICD-10-CM FY2027 · ICD-10-PCS FY2027 · HCPCS October 2026 · MS-DRG v44 · Medicare Code Editor v44.0 · NCCI PTP Q4 2026 · MUE Q4 2026 · NCD code lists 2026-01 · LCD export September 28, 2026 · All releases and sources
Summary
No tabular note links these codes. Both belong to category E11, and nothing in the tabular list prevents reporting each when it is documented.
Registry fact- What is different?
Title wording.The titles share “Type 2 diabetes mellitus with … ulcer”; E11.621 says “foot” where E11.622 says “other skin”.
Registry fact
Nothing found in 7 other checks
- Can these codes be reported together?
No instruction prevents it.No note in either entry names the other. Both belong to category E11; each may be reported when its own documentation is present.
Registry fact
- Is there an Excludes1 relationship?
None.Neither entry carries an Excludes1 note that names the other code. E11.621 carries 8 Excludes1 notes and E11.622 carries 8 Excludes1 notes covering other codes; the side-by-side table quotes them.
Official rule
- Is there an Excludes2 relationship?
None.Neither entry carries an Excludes2 note that names the other code.
Official rule
- Is one more specific?
No.Neither is a subdivision of the other, and neither title is the unspecified form; they describe different conditions within category E11.
Registry fact
- Is one a parent or header code?
No.Both are billable codes, and neither contains the other.
Registry fact
- Are there sequencing instructions?
None.Neither entry carries a Code First or Use Additional Code note that names the other.
Official rule
- Are there other coding relationships?
None found.No laterality, encounter-phase, Table of Neoplasms, Table of Drugs and Chemicals, or history-versus-active-disease relationship links these codes.
MedCoder-derived
Official rule: a tabular instructional note or a section of the ICD-10-CM Official Guidelines, quoted as published. Registry fact: the codes’ own published attributes (titles, billable status, position in the hierarchy, code set). MedCoder-derived: a reading MedCoder computes from those facts; it is not itself a rule. How to read the labels
Can these codes be reported together?
Yes, when each is documented. E11.621 and E11.622 both belong to category E11.
No Excludes1/Excludes2 relationship exists between these codes in the official tabular list. The code titles state what each one covers, and the documentation decides which applies.
Side by side
Similar descriptions do not make codes interchangeable. The documentation and the official instructions decide which code applies.
Type 2 diabetes mellitus with foot ulcer
Type 2 diabetes mellitus with other skin ulcer
- diabetes mellitus due to underlying condition (E08.-)
- drug or chemical induced diabetes mellitus (E09.-)
- gestational diabetes (O24.4-)
- neonatal diabetes mellitus (P70.2)
- postpancreatectomy diabetes mellitus (E13.-)
- postprocedural diabetes mellitus (E13.-)
- secondary diabetes mellitus NEC (E13.-)
- type 1 diabetes mellitus (E10.-)
- code to identify site of ulcer (L97.4-, L97.5-)
- code to identify site of ulcer (L97.1-L97.9, L98.41-L98.49)
Shared by both codes (5 notes)
- code to identify control using:
- injectable non-insulin antidiabetic drugs (Z79.85)
- insulin (Z79.4)
- oral antidiabetic drugs (Z79.84)
- oral hypoglycemic drugs (Z79.84)
E11 Type 2 diabetes mellitus
E00-E89 — Endocrine, Nutritional and Metabolic Diseases (E00-E89)
- diabetes (mellitus) due to insulin secretory defect
- diabetes NOS
- insulin resistant diabetes (mellitus)
No Excludes2, Code first, Code also and 7th character note at either code.
Notes are the code’s own tabular entry, quoted as published. A note that names the other code is the one the verdict above rests on. In a row that differs, each code’s own notes are listed under it, and the notes every code shares are listed once beneath them.
Editorial explanation — not an official CMS/CDC rule. Official coding instructions and source material are identified below. How to read the labels
The distinction
Both codes say the same two things — this patient has type 2 diabetes, and the diabetes is linked to a skin ulcer. They differ on one axis only: E11.621 is a foot ulcer, E11.622 is a skin ulcer anywhere else. The documented anatomical site decides it, and it also decides which range the required second code comes from.
The deciding question
Where is the ulcer, anatomically?
A foot ulcer selects E11.621, whose Use Additional Code note routes to the foot-specific L97.4- (heel and midfoot) and L97.5- (other part of foot) subcategories. An ulcer anywhere else on the skin selects E11.622, whose note routes to the wider L97.1–L97.9 and L98.41–L98.49 ranges. Neither diabetes code carries the ulcer’s site or severity itself, so in both cases the second code is required rather than optional — and category L97’s own Code First note names both diabetes codes as the underlying condition to sequence first.
Worked examples
Landing on E11.621
A type 2 diabetic is seen for a chronic ulcer of the right heel; the record documents the site but not the depth.
- E11.621 — Type 2 diabetes mellitus with foot ulcer (first-listed)
- L97.419 — Non-pressure chronic ulcer of right heel and midfoot with unspecified severity (secondary)
The heel is within the L97.4- subcategory the code’s note names. Severity is not documented, so the unspecified-severity option is what the classification provides; it is not an assumption about depth.
Landing on E11.622
A type 2 diabetic is treated for a chronic ulcer of the calf, with no severity documented.
- E11.622 — Type 2 diabetes mellitus with other skin ulcer (first-listed)
- L97.209 — Non-pressure chronic ulcer of unspecified calf with unspecified severity (secondary)
The calf is outside the foot subcategories, which is the whole distinction. The record names the site but neither the side nor the depth, so the unspecified-calf, unspecified-severity code is what it supports; documented laterality moves it to L97.21- or L97.22-, and documented depth moves it off the -9 severity character.
Why coders confuse them
The titles invite it: "foot ulcer" is concrete, but "other skin ulcer" reads like a catch-all for anything unusual rather than what it is — an ulcer that is simply not on the foot. Nothing in either title says that site is the only axis in play.
The same anatomical-site decision drives both the diabetes code and the required ulcer code, but the two code families express that site differently. A coder who has already picked the L97 or L98 code has effectively decided the diabetes code too, and working in the other order — diabetes code first, site code second — is where the mismatch creeps in.
Both codes are Excludes1-fenced against the other diabetes types (E08.-, E09.-, E10.-, E13.-, O24.4-, P70.2), so attention tends to go to establishing type 2 rather than to the site axis that actually separates this pair.
FAQ
Can either code be reported without an L97 or L98 code?
Not when the record locates the ulcer. Both carry a Use Additional Code note asking for the site code, and category L97 carries the reciprocal Code First note. Documentation that never states the site is a query opportunity, not a reason to report the diabetes code alone.
What if the ulcer is documented as healing?
The non-pressure ulcer guidelines say a healing ulcer is coded from the documentation, and that unspecified severity applies when the record does not describe it. A completely healed ulcer on admission gets no code, and documentation that is unclear about new versus healing should be resolved by querying the provider.
Does a toe ulcer count as a foot ulcer here?
The deciding element is whether the documented site falls in the foot subcategories the E11.621 note names — L97.4- and L97.5-, which cover the heel, midfoot, and other parts of the foot. Match the documented anatomical site to those subcategories rather than reasoning from the word "foot" alone.
Diabetes combination codes: how the E11 family is built·E11.628 — Type 2 diabetes with other skin complications
Derived from the official CMS ICD-10-CM tabular data (FY2027). A coding-rule comparison, not billing advice: payer-specific edits and medical-necessity policy are outside its scope. All data sources