An artificial intelligence (AI) tool can now flag a potential diagnosis before a human ever reviews the chart. Does that count as a query, and does it have to follow the same compliance rules as one written by a person?
According to the newly updated Guidelines for Achieving a Compliant Query Practice, released by AHIMA and the Association of Clinical Documentation Integrity Specialists (ACDIS), the answer is yes.
Query practices are evolving alongside new technologies that can identify potential documentation gaps earlier in the record review process. AI-generated prompts, electronic health records (EHR) alerts, and computer-assisted coding tools can now surface potential gaps before a clinical documentation integrity (CDI) or coding professional, or even the provider, ever looks at the record. The 2026 updated guidelines replace the 2022 edition and directly address this changing environment.
A query, broadly, is a request to a provider to clarify or expand on documentation in the record, whether written or verbal. The basic principles behind a compliant query haven't changed: queries should be based on actual clinical indicators, remain nonleading, and allow the provider to use independent clinical judgment.
What has changed is the environment in which queries are created, and that shift is exactly what the update addresses.
When Technology Generates a Query
The updated guidance makes an important point: a query is still a query, regardless of what technology creates it or where it appears.
Say an EHR trending tool notices a patient's creatinine rising over several draws and surfaces a message suggesting "acute kidney injury" as a documentation option, tied to that specific encounter. It doesn't matter if the system labels that message a "prompt," an "alert," or a "smart suggestion." If it presents a provider with a specific diagnosis or documentation option for a specific patient encounter, it functions as a query. That means it has to meet these same compliance standards as a manually written one:
- Relevant clinical indicators
- Nonleading language
- No reference to reimbursement
- Room for the provider to reach an independent conclusion
Organizations shouldn't assume that a vendor-supplied or EHR-integrated tool automatically produces compliant queries. The updated guidance emphasizes involving query professionals and compliance leaders in selecting, configuring, evaluating, and monitoring any technology that generates queries, not just at rollout, but on an ongoing basis as tools are updated or reconfigured.
A Closer Look at Clinical Validation
Clinical validation is one area where technology generated prompts raise particular compliance risk, and the updated guidance addresses it directly.
Clinical validation queries are used when a diagnosis is already documented in the record, but the clinical indicators needed to support it appear to be missing or insufficient. The goal isn't to tell the provider what to document. It's to have them review the evidence and reach their own clinical judgment about whether the diagnosis holds up.
That judgment matters beyond the chart. The provider's response reflects their clinical reasoning at the time of the query, based on the information available. It isn't meant to be reopened later as grounds for a claim denial, a post-payment audit finding, or an adverse coverage decision. Get the query wrong, and an organization risks more than a documentation gap; it risks the defensibility of the record itself.
Documentation affects many areas of healthcare, which is why the updated guidance encourages organizations to share and discuss it with professionals across quality, compliance, revenue cycle, patient financial services, physician groups, facility leadership, care management, informatics, and IT. This broader perspective is especially important as technology becomes more involved in the documentation process.
Principles Apply to Organizations of All Sizes
The guidance also recognizes that organizations have different resources and capabilities. Smaller organizations, including critical access hospitals, rural health clinics, and solo or small group physician practices, may not have the same technology, staffing, or governance structures as large health systems. The guidance allows these organizations to apply its principles based on their operational capacity. The way an organization oversees its query process may look different depending on its size, however, the expectation for what makes a query compliant does not.
The updated guidance goes into greater detail on query formats, verbal queries, multiple queries, the use of information from prior encounters, query templates, and other important aspects of a compliant query practice.
For anyone involved in documentation, coding, compliance, informatics, or related areas, the guidance is worth reading. You can read the guidelines online through ACDIS or the AHIMA Body of Knowledge.
In addition, a free webinar panel discussion on the guidelines will be presented September 30 at 1 p.m. ET. Experts who helped develop the updated guidance will discuss key changes, what CDI and coding professionals need to know, and how the updates may affect your organization’s query practices.
The webinar offers 1 ACDIS CEU, which can be used for renewal of CCDS/CCDS-O credentials or any AHIMA credential, for the live event only.
Rana Abuzir, RHIT, FACHDM, is director of health Information practice advancement at AHIMA.
By Rana Abuzir, RHIT, FACHDM