P28.4 vs R06.81
P28.4 (Other apnea of newborn) compared with R06.81 (Apnea, not elsewhere classified), from the official CMS tabular data. Do not report these codes together: the official tabular list marks them Excludes1.
Can these codes be reported together?
No — do not report together. R06.81 carries an Excludes1 note covering P28.4: “apnea (of) newborn (P28.4-)”
Sole exception: when the two conditions are documented as unrelated to each other (ICD-10-CM Official Guidelines, Section I.A.12.a).
Side by side
| P28.4Other apnea of newborn | R06.81Apnea, not elsewhere classified | |
|---|---|---|
| Billing status | Non-billable header | Billable |
| Classification | P00-P96 — Certain Conditions Originating in the Perinatal Period (P00-P96) | R00-R99 — Symptoms, Signs and Abnormal Clinical and Laboratory Findings, Not Elsewhere Classified (R00-R99) |
| Definition | Other apnea of newborn is a non-billable ICD-10-CM category code (P28.4). | Apnea, not elsewhere classified is a billable ICD-10-CM diagnosis code (R06.81). |
| Includes | — | Apnea NOS |
Derived from the official CMS ICD-10-CM tabular data (FY2026). Not billing advice; verify sequencing rules for the encounter. All data sources