Query Practice Brief Update: Is the Scope of Querying Too Broad?

Bear with me as I begin this article with the origins of health information (HI) professionals and the American Health Information Management Association (AHIMA).

HI professionals were once known as “medical record librarians” who were trained in library science, allowing them to collect, organize, index, and preserve patient records. AHIMA adopted its current name in 1991, as “data analytics and technology” began changing the landscape of clinical data and the need for management over the entire continuum of care.

Medical record librarians maintained the custody of the patient record; standardization, completeness, organization, and integrity of documentation; and stewardship of the medical record as a legal, clinical, and scientific artifact. Use of the International Classification of Diseases (ICD) supported HI efforts and allowed the reporting of morbidity and mortality data, which preceded creation of the Medicare Prospective Payment Systems (PPS) and Diagnostic-Related Grouping (DRG) Methodology.

Coding of the health record became an increasingly important business function when the Inpatient PPS (IPPS) was introduced in 1983. During this time, the Centers for Medicare & Medicaid Services (CMS, then known as the Health Care Financing Administration, or HCFA) was transitioning from a cost-based reimbursement model to control healthcare costs. AHIMA introduced the Certified Coding Specialist (CCS) credential in 1992.

Over time, as coders became more proficient using the ICD-9-CM code set and understood IPPS methodology better, the impact of adding a complication/comorbidity (CC) to a claim became clear, as it resulted in higher reimbursement. Some argue this is the origin of clinical documentation improvement (CDI). However, CDI really gained traction as a profession in 2008, with the release of Medicare Severity (MS) DRGs, whereby a diagnosis classified as a CC or major CC (MCC) could increase Medicare payments to a hospital. Eventually, the “I” was reframed from “improvement” to “integrity” as CDI tried to move away from its origins of revenue enhancement for traditional Medicare beneficiaries and into other areas, wherein clinical codes impact clinical data, like performance on quality-of-care measures.

Why the history lesson? Two reasons. First, this historical evolution matters because queries did not originate as a billing tool — yet today they are often governed as if they did. Second, I have heard concerns about the scope of the 2026 draft version of the Association of Clinical Documentation Integrity Specialists/American Health Information Management Association (ACDIS/AHIMA) query practice brief. Specifically, this paragraph:

“This practice brief should be shared and discussed with all healthcare professionals whose work intersects with health record documentation, including quality, compliance, revenue cycle, patient financial services, physician groups, facility leaders, care management, informatics, and information technology (IT). These disciplines impact the health record regarding reimbursement, medical necessity, professional billing, and quality, including complications, mortalities, clinical coding, and coded data (p 2).”

What is most confusing about this paragraph is how this practice brief should be discussed with these other stakeholders. Is it that they too must follow AHIMA guidance when asking the provider about documentation that affects elements of the clinical revenue cycle, like medical necessity? Is it that these other departments should send all requests for documentation clarification to CDI or coding professionals?

Or are queries necessary when it comes to clarifying patient status, because a query is defined as “a communication tool or process used to clarify documentation in the health record to ensure documentation integrity and the accuracy of diagnosis, procedure, or service code assignment (p. 4)?” The definition of a query appears limited, in the context of those who need to be educated about the query practice brief. The definition does not state that queries must be issued to clarify documentation that affects medical necessity.

Yet the scope of application reads that “the documentation query process is used for several initiatives, which include reimbursement methodologies, data stewardship and collection, quality measures, medical necessity, denial prevention, and related initiatives (p. 6).” This statement is followed by an example, noting that the brief should be applied including “quality team members seeing diagnosis clarification” related to quality measures.

The practice brief simultaneously constrains the definition of a query to code assignment while expanding its governance reach to activities that are not inherently coding‑driven. This creates operational ambiguity and fuels scope disputes. The brief also fails to distinguish between who uses clarification outcomes and who should govern the clarification process.

Should desired clarification outcomes drive the query process? It is the current process. We query because we want the provider to make a specific update to the record. Queries are rarely objective in practice. Should queries be required before any addendum or amendment can be made to the health record, except when the provider is correcting an error?

Health records are often plagued with inaccuracies. Some are impactful, such as documenting the wrong laterality of a body part affected by disease/injury, while others may be less impactful, but inaccuracy is often obvious, such as referring to a male patient as a female. The industry first needs to come to a consensus of what documentation requires a query for clarification. Should it be limited to documentation that can only be amended by the author of the original note? This would create a huge burden on providers. Additionally, is there some documentation that can be corrected by someone other than the provider who authored the note? Should HI professionals be allowed to remove inaccurate diagnosis codes from a problem list? After all, the problem list is a collection of diagnosis code titles, not authored clinical documentation.

What about when the health record is used for other purposes, like establishing medical necessity, which is not necessarily based upon code assignment? Should this type of provider communication require a query?

The concept of medical necessity is more than patient status alone. It is also used to justify the length of stay and certain procedures, and can be governed by National Coverage Determinations (NCDs) or Local Coverage Determinations (LCDs) within the Medicare population.

The accuracy of the health record is important for a variety of reasons, but we must always remember that the primary purpose of the health record is memorializing patient care. HI professionals have always been the stewards of health records and information governance. This is not an argument against HI governance; rather it is that the evolution of the health record and its uses need physician support. We need to move beyond query response rates and agreement rates as a tool to show provider engagement. Our current approach is not universally successful, as we continue to query the same issues year after year. Broadening the scope of querying may lead to unintended consequences, as providers already feel overwhelmed with documentation requirements.

As physician advisors become more prominent in the clinical revenue cycle, they should become partners in clinical information governance. They are well-positioned to work with both hospital and medical leadership to support a complete and accurate health record that faithfully represents patient care and supports downstream uses, including precise code assignment. Physician advisors make the perfect partner, because they are not only the authors of clinical documentation, but also consumers, when providing patient care. Not only should physician advisors share their feedback to AHIMA and ACDIS on the practice brief, but all CDI and HI professionals should share this draft practice brief with their clinical revenue cycle colleagues so they can offer feedback as well.