P28.81 vs R09
P28.81 (Respiratory arrest of newborn) compared with R09 (Other symptoms and signs involving the circulatory and respiratory system), 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. R09 carries an Excludes1 note covering P28.81: “respiratory arrest of newborn (P28.81)”
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
| P28.81Respiratory arrest of newborn | R09Other symptoms and signs involving the circulatory and respiratory system | |
|---|---|---|
| Billing status | Billable | Non-billable header |
| 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 | Respiratory arrest of newborn is a billable ICD-10-CM diagnosis code (P28.81). | Other symptoms and signs involving the circulatory and respiratory system is a non-billable ICD-10-CM category code (R09). |
Derived from the official CMS ICD-10-CM tabular data (FY2026). Not billing advice; verify sequencing rules for the encounter. All data sources