Respiratory distress of newborns and newborn respiratory failure P22.0 & P28.5

We just became aware of the new coding clinic regarding the assignment of RDS and newborn respiratory failure:   ICD-10-CM/PCS Coding Clinic, Second Quarter ICD-10 2019 Page: 29 Effective with discharges: June 21, 2019

There is an excludes 1 note that respiratory failure and RDS cannot be documented together.  Because there was no coding direction as to which condition could or had to be reported, HIM has been reporting P285 (respiratory failure) when both conditions are documented, as it was most appropriate.  But based on this new coding clinic, it sounds like AHA is now supporting that RDS should be reported over respiratory failure starting with discharges after 6/21/19.

Our denials team has been appealing any denials we get regarding this with that exact rationale, that there is not coding direction on which condition could/had to be reported, so the hospital can decide which one to report.  We are going to continue to appeal any of these with a discharge date prior to 6/21/19, but for those with a discharge date after 6/21/19, we probably won't have a leg to stand on.  Can anyone explain the rationale for the hospital not being able to choose which to code based on documentation?


  • short answer--RDS is basically considered the most severe form of respiratory failure in the newborn due to surfactant deficiency...similar to ARDS in an adult. Clinically, if you have a premature baby with respiratory failure it's almost always due to surfactant deficiency. Term baby--different story.
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