Your company is confusing the elements of chart auditing (i.e. 2/3 key components on an established patient), with the need for medical necessity.
Per CMS, Medical necessity (not MDM) is the overarching criteria for code selection. So your providers' note must illustrate whatever was performed/provided to the patient was necessary from a medical standpoint, and must make a case to support what the provider wishes to bill. It must also report that the care provided to the patient was necessary, complete, medically sound, and appropriate.
Let's say the established patient presents with a bruised foot, after a fall. I cannot think of any reason why an examination would not be performed, in order to rule out a fracture, or to determine if there is some other sort of injury, to determine if films should be taken, if a referral is appropriate or to figure out if a cast/splint should be applied in the office. To submit a claim for a foot injury with only an HPI and Assessment/plan without the provider having documented his or her objective examination is negligent. Sure, you can code it based on the HPI and Assessment and plan, but there's a large amount of information missing here. What if that injured foot led to complications or infection? The fact that your provider never documented that he did an exam is going to be questioned during litigation, and he will be hard pressed to explain why, as a licensed physician, he did not look at the patient's injured foot. Most lawsuits are not because providers knowingly did the wrong thing. Most lawsuits are the result of laziness.
Purposely omitting parts of the E&M visit just to get the claims out the door quickly is a very good example of risky behavior.