Study guide
10.2 ACDIS/AHIMA 2026 Guidelines for Achieving a Compliant Query Practice
Certified Clinical Documentation Specialist CCDS
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1 Introduction & Exam Overview
1.1 Current Exam Facts 1.2 Eligibility Pathways and the 2,000-Hour Year 1.3 Allowed Resources and Test-Day Rules 1.4 Recertification, Fees, and How This Guide Maps the Eight Domains
2 IPPS Foundations
2.1 How IPPS Works and How CMS Updates It 2.2 MS-DRG Assignment, Relative Weights, and Grouping 2.3 Provider and Clinical Staff Documentation Duties under IPPS
3 Severity, CMI, Medical Necessity, and Oversight
3.1 CC versus MCC Recognition and CC Exclusion Lists 3.2 Case Mix Index and Why CDI Tracks It 3.3 Two-Midnight Rule, Medical Necessity of Setting, and Principal Diagnosis 3.4 MAC, RAC, CERT, OIG, and Denial-Vulnerable Practices
4 Nervous and Respiratory System CDI
4.1 Nervous System Conditions for CDI 4.2 Acute and Chronic Respiratory Failure, ABGs, and Ventilation Support 4.3 Pneumonia, COPD, PE, Pleural Effusion, and Respiratory Infections
5 Circulatory, Digestive, Hepatobiliary, Musculoskeletal, and Skin CDI
5.1 Circulatory Disorders 5.2 Digestive and Hepatobiliary Disorders 5.3 Musculoskeletal and Skin
6 Endocrine, Nutrition, Kidney, and Hematologic CDI
6.1 Diabetes, Dehydration, and Obesity 6.2 Malnutrition Criteria, Severity, and Audit Risk 6.3 AKI, CKD Staging, UTI, and Urinary Stones 6.4 Anemia, Coagulation, Sickle Cell, Lymphoma, and Leukemia
7 Infectious Disease, Other MDCs, and Clinical Indicator Tools
7.1 Sepsis, Severe Sepsis, Postoperative and Other Infections 7.2 Mental, Substance Use, Injuries/Toxicology, and HIV-Related Conditions 7.3 Medications, Diagnostic Tests, and Abbreviations as Clinical Indicators
8 Health Record Elements and Query Triggers
8.1 Which Record Elements Support Diagnosis and Procedure Codes 8.2 Attending versus Radiologist, Pathologist, and Other Providers 8.3 When a Physician Query Is Warranted 8.4 When Queries Are Not Appropriate
9 Query Timing, Verbal Queries, Formats, and Clinical Indicators
9.1 Concurrent, Retrospective, Pre-Bill, and Prospective Timing 9.2 Verbal Queries and Required Documentation 9.3 Open-Ended, Multiple-Choice, and Yes/No 9.4 Clinical Indicators and How to Source Them
10 Compliant Query Practice and Clinical Validation
10.1 Compliant versus Leading and Other Noncompliant Queries 10.2 ACDIS/AHIMA 2026 Guidelines for Achieving a Compliant Query Practice 10.3 Clinical Validation and Diagnoses without Clinical Support
11 CDI Program Metrics
11.1 Productivity, Query Volume, and Provider Response Rates 11.2 CMI, CC/MCC Capture, and High-Frequency DRGs 11.3 SOI/ROM as CDI Program Performance Metrics
12 Physician Metrics, PEPPER, Forecasting, and Public Data
12.1 Measuring Physician Documentation Performance 12.2 PEPPER, Forecasting, Hospital Financial Data, and Public Reporting
13 CDI Roles, Coder Collaboration, and Physician Education
13.1 Roles and Responsibilities of the CDI Specialist 13.2 Coder Roles Working with a CDI Department 13.3 Physician Education Tools, Forms, and Presentations
14 Provider Communication and DRG Reconciliation
14.1 Non-Confrontational Communication and When Verbal Beats Written 14.2 Working DRG versus Final DRG Reconciliation
15 Official Guidelines, Principal Diagnosis, and Secondary Diagnosis
15.1 Official Guidelines, Cooperating Parties, Updates, and AHA Coding Clinic 15.2 Principal Diagnosis Selection 15.3 Secondary Diagnosis Reporting Criteria
16 Sequencing, Coding Conventions, and POA Indicators
16.1 Sequencing When Two Diagnoses Equally Meet PD; Working DRG with Multiple Diagnoses 16.2 Integral Signs/Symptoms, the With Convention, and Uncertain Diagnoses 16.3 Present-on-Admission Indicator Assignment and Payment Impact
17 Hospital-Acquired Conditions, Disposition, and ICD-10-PCS Essentials
17.1 CMS Hospital-Acquired Condition Payment Provision 17.2 Discharge Disposition, Transfer Payment, Principal Procedure, and ICD-10-PCS Essentials
18 Ethics, Privacy, and Leading Queries as Compliance Failures
18.1 ACDIS Code of Ethics and CDI Goals beyond Reimbursement 18.2 HIPAA, Minimum Necessary, and Record Confidentiality 18.3 Leading Queries as a Compliance Failure
19 DRG Creep, OIG Oversight, PEPPER, and the False Claims Act
19.1 DRG Compliance, DRG Creep, and the OIG Work Plan 19.2 PEPPER Compliance Risks and the False Claims Act
20 Mortality Index, Observed-to-Expected Ratios, and Quality Data Sources
20.1 Documentation Impact on Mortality Index (SOI/ROM) 20.2 Mortality Reviews and Observed-to-Expected Ratios 20.3 Abstracted versus Claims-Based Quality Data
21 CMS Quality Programs, PSIs, and Infection versus Complication Codes
21.1 HVBP, HAC Reduction Program, HRRP, 30-Day Mortality, and Hospital IQR 21.2 PSI 90 Components and PSIs beyond the Composite 21.3 Healthcare-Associated Infections versus Complication Codes
10.2 ACDIS/AHIMA 2026 Guidelines for Achieving a Compliant Query Practice
Key Takeaways Explain This Topic AI
The August 2026 ACDIS/AHIMA Guidelines for Achieving a Compliant Query Practice supersede the 2022 edition for current professional practice; ACDIS's live application page still lists the 2019 brief for its February 2022 exam form, so distinguish current practice from the published exam-source baseline.
The brief applies equally to inpatient, outpatient, ambulatory, professional-fee, and technology-generated queries; this inpatient guide emphasizes the inpatient application.
Substantial compliance means the four core elements are met; isolated technical deviations do not, standing alone, render a query noncompliant or justify claim denial.
Technology prompts, alerts, and nudges that present a specific diagnosis option for a specific patient are queries and follow the same standard as manual queries.
Actual queries must be a permanent part of the health record or retrievable in the business record, and diagnosis queries go to the treating provider for that encounter.
Last updated: September 2026
10.2 ACDIS/AHIMA 2026 Guidelines for Achieving a Compliant Query Practice
Quick Answer: The August 2026 ACDIS/AHIMA Guidelines for Achieving a Compliant Query Practice supersede the 2022 version. The brief applies across inpatient, outpatient, ambulatory, professional-fee, and technology-generated queries; this inpatient guide emphasizes the inpatient application of the same standard. Reviewers should look for substantial compliance with the four core elements, not isolated technical deviations. Keep the actual query in the health record or the business record . Query the treating provider for that encounter—not a physician advisor or medical director who never cared for the patient.
What changed in August 2026
ACDIS, an HCPro professional community, and AHIMA released the 2026 update as a position paper dated August 2026 . The opening of that brief states that it supersedes all previous versions, including the 2022 version , and reflects standards available as of its publication date. Independent ExamFinch teaching for CCDS candidates treats the 2026 brief as the source for current query practice . Older slides, facility templates, and audit tools built only to the 2022 edition are stale until they are reviewed against the update. This section is not an ACDIS or AHIMA product and does not claim official approval, review, or partnership with either organization.
Exam-source note: ACDIS's live application page still identifies its February 2022 exam form as using the 2019 query-practice brief. ACDIS has not yet added the August 2026 paper to that published exam-source list. If a stem asks for the current professional standard , use the 2026 paper; if it asks which source the current exam form is based on, use ACDIS's live application-page list. Recheck that page before the sitting.
The 2026 brief is a professional practice resource , not a statute and not a substitute for facility policy or for the independent authority of Centers for Medicare & Medicaid Services (CMS) contractors. It is intended to guide organizational policy, education, query audits, and denial defense. It is not written as a stand-alone rationale for claim denial, post-payment recovery, or an adverse audit finding. That last point matters on CCDS items that mix CDI operations with payer behavior: a Recovery Audit Contractor (RAC) or plan medical director who treats a missing source date as automatic DRG recoupment is using the brief in a way the brief itself rejects.
Substantive 2026 emphasis that inpatient specialists should be able to name includes a clearer substantial-compliance standard for external review, a fuller technology section (computer-assisted physician documentation, computer-assisted coding, large language models and other generative tools, and electronic health record alerts), guidance on prior encounters versus chart mining, and a definition of noncompliant multiple queries that turns on intent and pattern , not on a raw count.
Equal application, inpatient emphasis on this exam
The brief's guidance applies equally across inpatient, outpatient, ambulatory, and professional-fee environments, with outpatient-specific notes where Uniform Hospital Discharge Data Set (UHDDS) rules and present on admission (POA) do not apply. Any professional or technology that reviews the health record is expected to follow it. Quality nurses seeking measure clarification, sepsis coordinators seeking diagnosis validation, and electronic prompts that offer a diagnosis for a specific patient are all inside the tent.
This credential is inpatient CCDS (IPPS). Teach and test the inpatient application: UHDDS principal and secondary diagnosis reporting, POA, concurrent review during the stay, and query of the providers who are actually treating the admission. Do not drift into outpatient Hierarchical Condition Category (HCC) workflows except to remember that the 2026 brief would hold those prompts to the same nonleading and indicator standard —and that HCC work is a different credential ( CCDS-O ).
Substantial compliance versus isolated technical deviations
For purposes of the 2026 brief, substantial compliance means the query addresses the core requirements of a compliant query practice:
It is nonleading .
It includes clinically relevant and sourced indicators .
It does not reference reimbursement or quality outcomes .
It gives the provider an opportunity to exercise independent clinical judgment .
Isolated technical deviations do not, standing alone, render a query noncompliant when the overall query meets those core requirements. The brief's own illustrations of isolated misses include a minor formatting inconsistency, a missing source date on a single indicator, or a query title visible to the provider that is descriptive but not diagnosis-directing . Deviation from any specific element of the brief does not, standing alone, constitute evidence of a noncompliant query or support for a claim denial or payment adjustment.
That is not a license to skip sourcing. A query with no patient-specific indicators, or with indicators the query professional invented as diagnoses, fails a core requirement. Substantial compliance is a shield against nitpicking, not against leading queries or payment language.
Review finding 2026 brief treatment
Nonleading, sourced, no payment/quality language, independent judgment preserved Core met: substantial compliance
Missing date on one of several otherwise cited indicators Isolated technical deviation; not, by itself, noncompliant
- Visible title "CDI query — renal status" Descriptive, not diagnosis-directing
- Visible title that names the desired diagnosis Influencing title: core problem, not a nit
- "Please confirm the MCC" in the stem Reimbursement language: core failure
- Using the brief as the only reason to recoup an MS-DRG Inconsistent with the brief's purpose and scope
The brief is scalable . Critical access hospitals and small programs still owe the four core elements. They may size governance, template committees, and audit samples to their resources. They may not waive nonleading practice because the team is small.
Technology-generated queries follow the same standard
Section XI of the 2026 brief is explicit: technology-generated or automated queries , including communications labeled prompts, nudges, advisories, alerts, or similar terms, must include all elements of compliant query practice. Regardless of setting or who receives the message, technology-generated queries are subject to the same compliance standards as manually constructed queries. Organizations should not assume a vendor tool is compliant by default.
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 the label or the screen it lives on. Passive clinical decision support that surfaces reference information without directing the provider toward a specific response for a specific patient is not a query under that definition. When in doubt, treat the communication as a query.
Practical inpatient implications:
Computer-assisted physician documentation (CAPD) that pops "add acute respiratory failure?" during note writing is a query if it offers a diagnosis for this patient.
Computer-assisted coding (CAC) queues that ask a hospitalist to confirm a code after discharge are queries.
Generative artificial intelligence that drafts query language still owes sourced indicators, a nonleading stem, clinically relevant options, and an Other path. Humans remain responsible. Process owners retain accountability for every query delivered, including automated ones.
If a technology query does not yield the "desired" response, it is noncompliant to send a follow-up manual query to the same or a different provider in order to override that judgment.
Answer options must not use formatting, emphasis, or ordering that directs the provider toward a preferred response—the same highlighting ban as in 10.1.
Titles and subject lines visible to providers must not name a desired diagnosis, reimbursement impact, or quality measure.
Identification of a noncompliant technology-generated query should trigger the same escalation and corrective action used for any noncompliant query. Staff who use these tools need training on how to evaluate output against the brief, not only on how to click send.
Retention: health record or business record
Compliant practice requires that all actual queries either be a permanent part of the health record or be retrievable in the business record . Organizations choose the location; they do not choose to make queries untraceable. Best practice is for providers to incorporate answers into their own documentation, speaking to clinical significance. If a compliant query has been properly answered and authenticated by a responsible provider and is part of the permanent health record, that response is sufficient for code assignment and need not be repeated elsewhere. If later documentation conflicts with the query response, additional clarification is required.
Verbal queries are queries. They must capture date and time, participants, indicators and sources, a nonleading statement, options if any, and the verbal response, and they must be tracked like written queries. The provider's response must reach the permanent health record before the related code is assigned. If the provider spoke but did not document, work an addendum or a written query; do not code from hallway memory.
Policies should also state how long queries are kept, how technology-generated queries are archived, and who may access them for audit, coding, quality, and legal review. Retention is a compliance control, not optional filing.
Whom to query
Queries should be directed to and answered by the provider or providers who provided direct clinical assessment and care during the specific encounter . It is inappropriate to query a provider who was not directly involved. Documentation from a physician advisor , medical director, or other administrative role who did not participate in direct clinical care of that patient cannot be used as a query response for establishing the diagnosis—just as inpatient pathology or radiology text cannot, by itself, establish a medical diagnosis the treating team never adopts.
When multiple specialties are involved, send the query to the provider most appropriate for the subject . Do not send a skin-ulcer etiology question to the consulting nephrologist, and do not send the extent of the surgeon's excisional debridement to the hospitalist. When documentation conflicts , query the attending (as defined by organizational policy) to resolve the discrepancy. Additional specificity or new diagnoses from consultants, specialists, advanced practice providers, or emergency department providers are generally reportable without another query unless they conflict with the attending.
Clinicians who are not providers may be queried for facts other than a diagnosis —for example, a nurse for infusion administration, a respiratory therapist for mechanical ventilation hours, a dietitian for body mass index, or a radiologist for laterality of a lesion—when organizational policy allows. Those fact queries do not convert the ancillary clinician into the person who establishes the medical diagnosis.
In telehealth or remote monitoring, the brief's face-to-face idea is direct clinical involvement in the encounter, not physical presence in the room. For inpatient CCDS, the operational translation is still: query the people who treated this admission .