I too feel the same...here only alcohol withdrawal seizure. 291.81 and 789.39 is enough I think.
See the coding clinic description here
Alcohol Withdrawal Seizure and Epilepsy
Coding Clinic, Second Quarter 2012 Page: 9
Coding advice or code assignments contained in this issue effective with discharges July 17, 2012.
Question:
A patient with chronic alcoholism and a history of epilepsy is admitted with alcohol withdrawal seizures. Is it appropriate to code both seizure due to alcohol withdrawal (780.39) and epilepsy (345.90)?
Answer:
Yes, it is appropriate to assign both codes, if the provider has documented that the patient has both alcohol withdrawal seizures and epilepsy. Assign codes 291.81, Alcohol withdrawal, and 780.39, Other convulsions, for alcoholic withdrawal seizures. Also assign codes 345.90, Epilepsy, unspecified, without mention of intractable epilepsy, and 303.90, Other and unspecified alcohol dependence.
Although subcategory 780.3, Convulsions, excludes epileptic convulsions, in this case, the patient has both conditions. A patient may experience seizures due to alcohol withdrawal, because of the lack of alcohol in the system. This type of seizure can affect anyone who abuses alcohol chronically and suddenly stops; however, people with epilepsy have a higher incidence
Thara L CPC H