A Critical Query Practice Brief Comment Period

An update to the 2022 Query Practice Brief was released for comment last week during the 2026 National Association of Clinical Documentation Integrity Specialists (ACDIS) Conference in Chicago. This update resulted in a significantly longer document than previous practice briefs, at 37 pages, but is well-constructed with meaningful sections.

The draft version of the Guidelines for Achieving a Compliant Query Practice Brief 2026 is available on the ACDIS website for both members and nonmembers alike. The comment period is open until May 16. As a past contributor to several editions of the query practice brief and all versions of the clinical validation practice briefs, I thought it might be helpful to share some key updates over the next couple of weeks.

Use of the ICD-10-CM code set to report diagnoses in all healthcare settings is required under the Health Insurance Portability and Accountability Act (HIPAA) of 1996 and subsequent legislation. Therefore, adherence to ICD-10-CM guidelines, a set of rules developed to accompany and complement the official conventions and instructions provided within ICD-10-CM, is also required. Although ICD-10-CM guidelines include instructions “to query the provider” when clarity is required, the guidelines do not define the query process.

The American Health Information Management Association (AHIMA), which is also a Cooperating Party for ICD-10-CM, was authorized by the Health Care Financing Administration (HCFA), the federal agency that preceded the Centers for Medicare & Medicaid Services (CMS), to establish industry query guidance in 2001. Sue Prophet, the Director of Coding and Policy Compliance for AHIMA at the time, advocated on behalf of coders for queries as a tool to address incomplete, untimely, and inaccurate provider documentation. HCFA decided to allow the use of queries if they:

1. Are not leading (no further definition included);
2. Do not introduce new information not otherwise contained in the medical record;
3. Provide clarification; or ​
4. Remain consistent with other medical record documentation. ​

The query practice brief is industry guidance. It is not binding on either hospitals or payers. Professional coders are not legally required to follow the Query Practice Brief solely because of AHIMA authorship or credentialing. However, the brief represents the nationally recognized industry standard for compliant query practice, and is routinely relied upon by auditors, payers, and regulators, regardless of a coder’s credentialing body.

The authors of this update thoughtfully addressed the weaponization of queries by payers by noting that the Query Practice Brief “is not intended for use as a basis for denying claims or disputing clinical queries.” They continue by stating that the practice brief is not to be used as “a stand-alone rationale for claim denial, post-payment recovery, or adverse audit finding.”

The authors conclude by asserting that “substantial compliance with the principles in this brief, rather than rigid technical adherence to any specific element, is the appropriate standard for external review.” While this language does not prohibit payers from reviewing queries, it directly challenges the practice of denying compliant documentation solely due to technical query critiques. I applaud the authors for including this particularly important section within the Query Practice Brief. I hope it will reverse the trend of payers removing a complication/comorbidity or major complication/comorbidity (CC or MCC) from a claim because the payer considers a query to be noncompliant.

As the complexity of hospital reimbursement has grown, so has the need for accurate and complete provider documentation. Querying, which was once the domain of professional coders, is also performed by other revenue cycle departments. In some hospitals, querying is the sole responsibility of clinical documentation integrity (CDI) professionals. However, the purpose of querying is the same regardless of which department performs the query function within a healthcare organization.

The primary difference between querying performed by CDI and that which is performed by coding professionals is the timing of when querying occurs. CDIs are typically reviewing the health record concurrently, while coders are often reviewing the health record retrospectively. Most hospitals have found that query response rates are higher when the query is issued while the patient is still being treated (concurrently), because queries are more visible to the provider, and additional documentation can be more easily incorporated into the health record.

What constitutes querying is expanded in this 2026 update, beyond those who perform CDI and coding functions, to include documentation related to “quality measures, medical necessity, denial prevention, and related initiatives.” As technology is introduced into revenue cycle processes, many companies launched “front-end” tools that “nudge” providers to document using terms that support ICD-10-CM code assignment at the point of care. The 2026 update also states that “any professional or technology that reviews the medical record, whether in the inpatient, outpatient, or professional fee setting, should take into account compliant practices and follow the instructions within the brief.”

In my opinion, the contributors to this Query Practice Brief update did a wonderful job clarifying that it will apply to both manually constructed and technology-generated queries, regardless of the term used to solicit additional information from a provider (e.g., prompts, nudges, advisories, alerts, or similar terms) in any setting. The practice brief clearly states that “a communication constitutes a query when it presents a provider with a specific diagnosis or documentation option for consideration in connection with a specific patient encounter, regardless of how the communication is labeled or where it appears within the technology platform.”

Querying is a crucial tool because an effective query process resolves documentation issues prior to coding, thereby minimizing billing delays. Although this topic is not addressed within the Query Practice Brief itself, best practice is for queries to be resolved prior to coding, which typically occurs between two to five days following discharge. A key performance indicator for many revenue cycles is how long it takes to finalize and bill a claim, often referred to as Discharged Not Final Billed (DNFB) or bill-hold times. Long DNFB times directly increase another hospital metric, days in accounts receivable (A/R), which measures the average number of days it takes a hospital to get paid after hospital care is rendered.

Next week, I will explore query guidelines, standards, and definitions.