Final/updated ACDIS/AHIMA physician query practice brief is out: What does it say?
The final (revised/updated) ACDIS-AHIMA Guidelines for Achieving a Compliant Query Practice—2022 Update was released on Wednesday, Dec. 14th. What’s in it?
If you’re a CDI or coding professional you need to read it. The link is below; the document is open source/free and available on the ACDIS website.
A few items that jumped out at me.
The most obvious is the inclusion of a lengthy frequently asked questions (FAQ) section at the end. While far too much to cover here, it includes questions on whether CDI should police other departments; whether it’s permissible to include definitions within a query; what “mining” for a diagnosis means, and much more.
This Q&A interested me:
Question: For prospective chart reviews that are not associated with any encounter and are not querying providers to make changes to past encounters, do the query guidelines apply?
Answer: Yes, all queries should follow the same guidelines. Because of the shortened time of an outpatient encounter, a concurrent review may not be practical. The need for query may be based off current and previous documentation, the problem list, and any diagnostic data available—knowing a query should not be asked unless it is relevant to the planned encounter. Such queries should be crafted with the guidance of the practice brief.
So, the brief makes it clear that the guidelines apply to outpatient query practice, too. This makes sense if the chart is being prospectively reviewed by a CDI or coding professional, but puts a lot of pressure on any technology vendor who uses real-time CAPD prompts.
The Q&A on mining asks the paper authors to define that term, which they do as follows:
The goal of this statement is to guide query professionals as to when it is appropriate to source clinical indicators from previous encounters. The process of mining is when one consults health information from prior encounters without any guiding reason or focus, just reviewing to identify diagnosis or condition specificity that is not related to the present encounter. Organizations should develop policies related to when and for what reasons prior encounters can be reviewed, to include how old the records should be.
This is important guidance to reference when using prior records to query providers. While referencing prior records is a permissible practice, the diagnosis/condition you’re seeking to clarify should relate to the present encounter. Don’t go back to old records and query for past acute conditions that may add HCC weight but no longer have relevance.
In general the brief throws out a very wide net; it applies not only to queries that add specificity to diagnoses and procedures used for accurate ICD-10-CM/PCS assignment, but also CPT (proprietary codes owned by the AMA) and even welcomes it as reference for the OIG and payer review agencies. It applies to everyone who might query a provider, including those you might not expect (infection control clinicians are cited, for example). Anyone who might impact claims data falls under its wide net.
The two associations also published a lengthy list of acknowledgements, demonstrating that more than just a small group of HIM/CDI professionals had input into this document.
I thank all involved in its creation. I know these guidelines are a lot of work, and require organizing meetings on busy people’s schedules, establishing an outline of what they will cover and what they won’t, agonizing over word choice and words that will be endlessly reviewed and debated (“it depends on what the meaning of the word ‘is,’ is”), and engaging in hard conversations and disagreement.
Even if you don’t agree with everything in the brief, the fact that we have this guidance is welcomed. We need rules of the game that everyone follows.
I suspect this document will spark broader industry-wide commentary on the intersection of coding rules and clinical practice, and humans and technology.
Read the brief here on the ACDIS website: https://acdis.org/resources/guidelines-achieving-compliant-query-practice%E2%80%942022-update
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