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E11.621 vs L97.4

E11.621 (Type 2 diabetes mellitus with foot ulcer) compared with L97.4 (Non-pressure chronic ulcer of heel and midfoot), 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

These codes can be reported together, with E11.621 sequenced before L97.4 as the tabular note instructs.

Official rule
What is different?

The conditions named, billing status and chapter.E11.621 is “Type 2 diabetes mellitus with foot ulcer”; L97.4 is “Non-pressure chronic ulcer of heel and midfoot”. L97.4 is a non-billable header; E11.621 is billable. E11.621 sits in E00-E89 — Endocrine, Nutritional and Metabolic Diseases (E00-E89); L97.4 in L00-L99 — Diseases of the Skin and Subcutaneous Tissue (L00-L99).

Registry fact

Can these codes be reported together?

Yes, in the order the notes give.E11.621 is listed before L97.4; the sequencing answer below quotes the instruction.

Official ruleGuide: Code First vs Use Additional Code vs Code Also

Is one a parent or header code?

One is a header.L97.4 is a non-billable header, but E11.621 is not one of its subdivisions.

Registry fact

Are there sequencing instructions?

Yes.Sequence E11.621 before L97.4: L97.4 carries a Code First instruction covering E11.621 (“diabetic ulcers (E08.621, E08.622, E09.621, E09.622, E10.621, E10.622, E11.621, E11.622, E13.621, E13.622)”); E11.621 carries a Use Additional Code instruction covering L97.4 (“code to identify site of ulcer (L97.4-, L97.5-)”).

Official ruleGuide: Code First vs Use Additional Code vs Code Also

Nothing found in 3 other checks; 1 check does not apply
Is there an Excludes1 relationship?

None.Neither entry carries an Excludes1 note that names the other code. E11.621 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. L97.4 carries 3 Excludes2 notes covering other codes; the side-by-side table quotes them.

Official rule

Is one more specific?

Not comparable.The codes sit in different categories; specificity is only comparable within one category.

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 — in the order the notes give.

No Excludes1/Excludes2 relationship exists between these codes in the official tabular list. The sequencing instruction below sets which code is listed first on the claim.

Sequencing on the claim

Sequencing

Sequencing relationship

1st
E11.621
Type 2 diabetes mellitus with foot ulcer
→
then
L97.4
Non-pressure chronic ulcer of heel and midfoot

What we found

Sequence E11.621 before L97.4

E11.621 carries a Use Additional Code instruction covering L97.4: “code to identify site of ulcer (L97.4-, L97.5-)”

L97.4 carries a Code First instruction covering E11.621: “diabetic ulcers (E08.621, E08.622, E09.621, E09.622, E10.621, E10.622, E11.621, E11.622, E13.621, E13.622)”

What to review

On a claim that carries both, list E11.621 ahead of L97.4; the manifestation is never the principal diagnosis.

Guide: Code First vs Use Additional Code vs Code Also

Why it matters

A "Code first" note means the underlying etiology is sequenced ahead of this manifestation code on the claim.

Source / rule

CMS ICD-10-CM tabular instructional notes

Official guidance behind these answers

  • Section I.B.7 — Multiple coding for a single condition · applies to: Code first / Use additional code

    In addition to the etiology/manifestation convention that requires two codes to fully describe a single condition that affects multiple body systems, there are other single conditions that also require more than one code. “Use additional code” notes are found in the Tabular List at codes that are not part of an etiology/manifestation pair where a secondary code is useful to fully describe a condition. The sequencing rule is the same as the etiology/manifestation pair, “use additional code” indicates that a secondary code should be added, if known. For example, for bacterial infections that are not included in chapter 1, a secondary code from category B95, Streptococcus, Staphylococcus, and Enterococcus, as the cause of diseases classified elsewhere, or B96, Other bacterial agents as the cause of diseases classified elsewhere, may be required to identify the bacterial organism causing the infection. A “use additional code” note will normally be found at the infectious disease code, indicating a need for the organism code to be added as a secondary code. “Code first” notes are also under certain codes that are not specifically manifestation codes but may be due to an underlying cause. When there is a “code first” note and an underlying condition is present, the underlying condition should be sequenced first, if known. […]

    ICD-10-CM Official Guidelines FY2027

  • Section I.A.13 — Etiology/manifestation convention (“code first”, “use additional code” and “in diseases classified elsewhere” notes) · applies to: Etiology/manifestation convention

    Certain conditions have both an underlying etiology and multiple body system manifestations due to the underlying etiology. For such conditions, the ICD-10-CM has a coding convention that requires the underlying condition be sequenced first, if applicable, followed by the manifestation. Wherever such a combination exists, there is a “use additional code” note at the etiology code, and a “code first” note at the manifestation code. These instructional notes indicate the proper sequencing order of the codes, etiology followed by manifestation. In most cases the manifestation codes will have in the code title, “in diseases classified elsewhere.” Codes with this title are a component of the etiology/ manifestation convention. The code title indicates that it is a manifestation code. “In diseases classified elsewhere” codes are never permitted to be used as first listed or principal diagnosis codes. They must be used in conjunction with an underlying condition code and they must be listed following the underlying condition. See category F02, Dementia in other diseases classified elsewhere, for an example of this convention. There are manifestation codes that do not have “in diseases classified elsewhere” in the title. For such codes, there is a “use additional code” note at the etiology code and a “code first” note at the manifestation code, and the rules for sequencing apply. […]

    ICD-10-CM Official Guidelines FY2027

Quoted from the ICD-10-CM Official Guidelines for Coding and Reporting in effect for the release shown. The tabular notes above are the code-level instruction; these sections are the convention that says how such a note is applied. Source document (CMS PDF) · Release and checksum

Side by side

Similar descriptions do not make codes interchangeable. The documentation and the official instructions decide which code applies.

Official descriptionDiffers
E11.621

Type 2 diabetes mellitus with foot ulcer

L97.4

Non-pressure chronic ulcer of heel and midfoot

StatusDiffers
E11.621
Billable
L97.4
Non-billable header

A header is not reported on a claim; a code beneath it is.

Report instead: L97.401, L97.402, L97.403, L97.404, L97.405

Excludes1Differs
E11.621
  • 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.-)
L97.4

None at this code

Excludes2Differs
E11.621

None at this code

L97.4
  • pressure ulcer (pressure area) (L89.-)
  • skin infections (L00-L08)
  • specific infections classified to A00-B99
Code firstDiffers
E11.621

None at this code

L97.4
  • any associated underlying condition, such as:
  • any associated gangrene (I96)
  • atherosclerosis of the lower extremities (I70.23-, I70.24-, I70.33-, I70.34-, I70.43-, I70.44-, I70.53-, I70.54-, I70.63-, I70.64-, I70.73-, I70.74-)
  • chronic venous hypertension (I87.31-, I87.33-)
  • diabetic ulcers (E08.621, E08.622, E09.621, E09.622, E10.621, E10.622, E11.621, E11.622, E13.621, E13.622)
  • postphlebitic syndrome (I87.01-, I87.03-)
  • postthrombotic syndrome (I87.01-, I87.03-)
  • varicose ulcer (I83.0-, I83.2-)
Use additional codeDiffers
E11.621
  • code to identify site of ulcer (L97.4-, L97.5-)
  • 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)
L97.4

None at this code

CategoryDiffers
E11.621

E11 Type 2 diabetes mellitus

L97.4

L97 Non-pressure chronic ulcer of lower limb, not elsewhere classified

ChapterDiffers
E11.621

E00-E89 — Endocrine, Nutritional and Metabolic Diseases (E00-E89)

L97.4

L00-L99 — Diseases of the Skin and Subcutaneous Tissue (L00-L99)

IncludesDiffers
E11.621
  • diabetes (mellitus) due to insulin secretory defect
  • diabetes NOS
  • insulin resistant diabetes (mellitus)
L97.4
  • chronic ulcer of skin of lower limb NOS
  • non-healing ulcer of skin
  • non-infected sinus of skin
  • trophic ulcer NOS
  • tropical ulcer NOS
  • ulcer of skin of lower limb NOS
  • Non-pressure chronic ulcer of plantar surface of midfoot

No 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.

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