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Compare/P28.5 vs R06

P28.5 vs R06

P28.5 (Respiratory failure of newborn) compared with R06 (Abnormalities of breathing), 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 carries an Excludes1 note covering P28.5: “respiratory failure of newborn (P28.5)”

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

P28.5Respiratory failure of newbornR06Abnormalities of breathing
Billing statusBillableNon-billable header

Report instead: R06.00, R06.01, R06.02, R06.03, R06.09

ClassificationP00-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)
DefinitionRespiratory failure of newborn is a billable ICD-10-CM diagnosis code (P28.5).Abnormalities of breathing is a non-billable ICD-10-CM category code (R06).

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