Flip side
Under Preventive Medicine Services header in CPT it states: "If an abnormality is encountered or a preexisting problem is addressed in the process of performing an preventive medicine E/M service AND if the problem or abnormality is significant enough to require additional work to perform the key components of a problem-oriented E/M, the the appropriate office/outpatient code 99201-99215 should be added..."
By that definition, the AMA is defining a non-preventive E/M as something that requires additional work to perform history, exam, and/or MDM. Take the "in addition to language" away because its not relevant to the point, but it does define the problem-oriented E/M.
Additionally, Medicare covers services based on "reasonable and medically necessary" criteria of which one could easily argue an annual review of medication is exactly that. And in the example you gave, wouldn't your doctor perhaps do a foot exam because the patient is diabetic or order a lipid panel to evaluate the hyperlipidemia? If so, I'd say that certainly qualifies as "additional work" for MDM and meets the above criteria.
This is a judgment call, but either answer is arguable.
Best of luck!