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Wiki Rules of "code first" for Z09/Z86/Z87?

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Springfield, IL
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Codes Z86 and Z87 tell you to code Z09 first if it is a follow up. However, my question is - do these codes NEED the Z09 at all? For example, if the visit is not a follow-up visit for that specific issue, but they have a past history of that issue, is the Z09 code still required?
 
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