I don't think you will find an answer to this in any official guidelines. None of the guidelines I'm familiar with say that you cannot use the information in the chief complaint as part of the HPI, and in my opinion, there would be nothing wrong with doing this. It is not 'double dipping' because you aren't count any 'points' in a chief complaint in order to meet a certain level. There no reason I can see that the information in the CC couldn't be used toward history, and there would be no logical reason to require a provider to record the information twice just in order to count it. CMS guidelines only state that the "the medical record should clearly reflect the chief complaint", so the record is required to contain this information, but it doesn't specify that it needs to be kept separate from the history. That's just my take on it, but hope it helps some.