P28.81
BillableRespiratory arrest of newborn
Last updated: FY2026 ICD-10-CM (Oct 1, 2025 – Sep 30, 2026) | CMS-HCC V28 (100% phase-in, PY2026)
Is P28.81 an HCC code?
Yes. P28.81 maps to Respiratory Arrest under the CMS-HCC V28 risk adjustment model.
HCC Category Mapping
RAF weights shown are the community, non-dual, aged base weights from the CMS risk adjustment model file. Actual per-patient RAF contribution depends on member segment, interactions, and the model year used by the payer. V28 is the CMS-HCC model phased in over payment years 2024–2026; V24 remains in use during the transition and for historical data.
MEAT Criteria for P28.81
For P28.81 to count as a valid HCC diagnosis in a given encounter, the provider's documentation must show MEAT: Monitor, Evaluate, Assess, or Treat. A diagnosis from a prior year does not carry forward automatically — it has to be re-documented and supported each calendar year.
- MMonitor: signs, symptoms, disease progression, or lab trending documented in the note
- EEvaluate: test results, medication response, or physical findings reviewed by the provider
- AAssess: explicit mention in the assessment or plan with acknowledgment of status
- TTreat: medication, referral, procedure, therapy, or counseling tied to the diagnosis
Only one of M/E/A/T is required to support the code, but the documentation must be specific enough to show that the provider actually addressed P28.81 during that encounter — not just copy-forwarded from a problem list.
What This Code Means
P28.81 is the ICD-10-CM diagnosis code for respiratory arrest of newborn. A newborn has a sudden, complete cessation of breathing that requires immediate intervention to restore spontaneous respiration. P28.81 sits in the ICD-10-CM chapter for certain conditions originating in the perinatal period (p00-p96), within the section covering respiratory and cardiovascular disorders specific to the perinatal period (p19-p29).
Under the CMS-HCC V28 risk adjustment model, P28.81 maps to Respiratory Arrest (HCC 212) with a community, non-dual, aged base RAF weight of 0.297. P28.81 was not retained as a payment HCC under the older V24 model, so V28 introduced or recategorized it during the 2024–2026 phase-in. V28 is the CMS-HCC risk adjustment model that reached 100% phase-in for payment year 2026, replacing V24 which was used during the PY2024–PY2025 transition.
Respiratory arrest is a critical condition; document the circumstances and interventions performed. Because P28.81 maps to a payment HCC, the provider's documentation must satisfy MEAT criteria (Monitor, Evaluate, Assess, or Treat) for the encounter to count toward the patient's Medicare Advantage risk adjustment score. When documentation is ambiguous, coders should issue a provider query rather than assume the highest-specificity variant.
HCC Buddy maintains structured V28 and V24 mapping, RAF weights, and MEAT documentation criteria for P28.81 sourced directly from the CMS-HCC risk adjustment model files and the CMS ICD-10-CM code set.
Coding Tips
- •Respiratory arrest is a critical condition; document the circumstances and interventions performed
- •Distinguish from apnea (temporary cessation) versus arrest (complete cessation requiring intervention)
Clinical Significance
Respiratory arrest of newborn represents complete cessation of breathing, constituting a medical emergency requiring immediate resuscitation. This condition carries extremely high morbidity and mortality risk, with potential for severe neurological complications if not rapidly reversed through aggressive intervention and life support measures.
Documentation Requirements
- ✓Documentation of complete cessation of breathing
- ✓Immediate resuscitation efforts provided
- ✓Gestational age and birth weight
- ✓Duration of respiratory arrest if known
- ✓Associated cardiac status during event
- ✓Interventions used for resuscitation
- ✓Neurological assessment post-event
- ✓Underlying precipitating factors