H.R. 1 Impact on Coding
Timothy Powell, CPA, CHCP
December 15, 2025
H.R. 1 doesn’t directly rewrite ICD-10 or CPT, but it does change the environment in which you’re coding. The impact is mostly indirect – through
AHIMA makes policy recommendations for SDoH.
Last month the American Health Information Management Association (AHIMA), in partnership with the National Opinion Research Center (NORC) at the University of Chicago, released their final report on Social Determinants of Health (SDoH) Data. The survey was completed with a little more than 2,600 respondents to obtain a better understanding of how SDoH information is collected, coded, and used to inform the development of potential educational tools and resources that may be needed for health information professionals, as well as guidance for policy recommendations.
The report found that about 78 percent of respondents confirmed that their organization is collecting SDoH data primarily through electronic means, typically through the electronic medical record (EMR). Regarding the most prevalent SDoH domains, it appeared that collecting information for health and health behaviors was the highest priority among healthcare organizations. Examples of this information include health insurance coverage and health factors such as smoking history and drug or alcohol utilization. One can understand why this is easily collected data, as any service requires registration of health insurance/coverage benefits, and tobacco and substance use history is a standard in nursing and physician documentation.
The second-most common factor was housing insecurity, followed by economic insecurity. However, after that it was really a grab bag of other SDoH factors in the rankings.
One of the policy recommendations from AHIMA was to create standardized, clinically valid, and actionable data elements for collection. I would strongly request that organizations follow the Centers for Medicare & Medicaid Services (CMS) social drivers of health, which at this time has prioritized housing, food, utility, transportation insecurity, and personal safety as the top issues.
However, I would absolutely agree with AHIMA that CMS’s quality metrics should be used in concert with the push for CMS’s SDoH z-code capture.
Additionally, the report found that although the majority of respondents are consistently using ICD-10-CM for coding and collecting SDoH data, the tools that are utilized to screen and assess members are widely different. There was also a significant decline in the integration of this information into workflows after the data was collected. Obviously, the challenges inherent in this discrepancy were cited as being related to lack of training in how to find these details in the medical record (and then what to do with it once it has been collected). The limitations are likely tied to AHIMA’s second policy recommendation, which is the request for CMS to align financial incentives with these efforts around SDoH.
I would absolutely agree with this request, as the amount of work needed to care for patients that struggle with such SDoH factors as housing insecurity significantly impacts the resources and amount of care medically needed for this population. Recognition of these efforts beyond internal data collection would absolutely go a long way.
Programming note: Listen to live reports on SDoH with Tiffany Ferguson Tuesdays on Talk Ten Tuesdays with Chuck Buck and Dr. Erica Remer, 10 Eastern.
Resource:
H.R. 1 doesn’t directly rewrite ICD-10 or CPT, but it does change the environment in which you’re coding. The impact is mostly indirect – through
In the CY 2026 Physician Fee Schedule (PFS) Final Rule, the Centers for Medicare & Medicaid Services (CMS) made significant changes to the applicable use
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