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Risk factor for destruction of lesions?

Hi,
We are having a debate whether destruction of benign or malignant lesions 17000-17110 are considered a *Minor Surgery WITH Identified Risk Factors, or Minor Surgery WITH NO Identified Risk Factors* under the Management Options category when coding EM levels.
For example sake, lets say pt otherwise has 3 additional diagnoses plus treatment for AK, a Detailed History and EPF skin exam, no additional treatment.
Note says pt was told what to expect after the procedure (blistering, bleeding, flake and fall off in a few days etc) and pt is given post treatment instructions. We have considered this under LOW risk (minor surgery with no identified risk factors) and are being told it should be considered as MODERATE with identified risk.

How would you consider the risk factor for this type of procedure and why?
Thanks!

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