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P28.5 vs P28.81

P28.5 (Respiratory failure of newborn) compared with P28.81 (Respiratory arrest of newborn), from the official CMS tabular data. Both may be reported when both conditions are documented (Excludes2).

Can these codes be reported together?

Yes, when both are documented. P28.5 carries an Excludes2 note covering P28.81: “respiratory arrest of newborn (P28.81)”

Excludes2 marks distinct conditions — both may be reported when both are documented.

Side by side

P28.5Respiratory failure of newbornP28.81Respiratory arrest of newborn
Billing statusBillableBillable
ClassificationP00-P96 — Certain Conditions Originating in the Perinatal Period (P00-P96)P00-P96 — Certain Conditions Originating in the Perinatal Period (P00-P96)
DefinitionRespiratory failure of newborn is a billable ICD-10-CM diagnosis code (P28.5).Respiratory arrest of newborn is a billable ICD-10-CM diagnosis code (P28.81).

Derived from the official CMS ICD-10-CM tabular data (FY2026). Not billing advice; verify sequencing rules for the encounter. All data sources