995.91 is not allowed first listed. The guidelines for septic shock:
Septic shock
(a)
Sequencing of septic shock
Septic shock generally refers to circulatory failure associated with severe sepsis, and, therefore, it represents a type of acute organ dysfunction.
For all cases of septic shock, the code for the systemic infection should be sequenced first, followed by codes 995.92 and 785.52. Any additional codes for other acute organ dysfunctions should also be assigned. As noted in the sequencing instructions in the Tabular List, the code for septic shock cannot be assigned as a principal diagnosis.
(b)
Septic Shock without documentation of severe sepsis
Septic shock indicates the presence of severe sepsis.
Code 995.92, Severe sepsis, must be assigned with code 785.52, Septic shock, even if the term severe sepsis is not documented in the record. The “use additional code” note and the “code first” note in the tabular support this guideline.
Also the guidelines state if the systemic infection is not documented then you code 038.9 first listed.