Dr. Timothy Dauwalder - California Hospice and Palliative Care
Transcription
Dr. Timothy Dauwalder - California Hospice and Palliative Care
Dr. Timothy Dauwalder Executive Medical Director VNA and Hospice Care of Southern California Palliative Care Consultant HMD Purpose? Referrals IPA/ACO/Hospitalist …PCP IDG Old rationale: Sign and dash Referral source without leadership or understanding of team IDG Accurate rationale: Team member Signature means understanding care plan Professional prognostic opinion Medical oversight of non-hospice and hospice plan of care including medication Education Policy expertise Resource for team Who should be your HMD? ??? Qualifications of HMD Hospice and Palliative Care Board Certified ? HMD Certification ? ….. HMD required to know policy… CTI Medical director vs. attending Policy continued FTF LCD’s/Coding Policy continued Technical denials MediCal HMO contract (passive enrollment) MediCare part D IDT (IDG): Defines HMD Team Survey of Hospice Staff Important qualities in an HMD? Results of all disciplines except administration and marketing Note: Results are prioritized differently for each discipline Responses in relative order of frequency 1. Accessible to staff 2. Availability and orders in timely manner (answers phone) 3. Respect nurses’ knowledge 4. Approachable to all disciplines 5. Actively listens to staffs and families 6. Bedside manner, kindness, empathy, compassion, humor More personality traits than …. Continued: 7. Comfortable in sharing concerns 8. Diverse and extensive palliative care experience 9. Good understanding of multiple coexisting complex diseases 10. Confident in prescribing hospice meds 11. Efficient with supportive paperwork for social work Continued: 12. Able to explain medical knowledge in understandable manner 13. Pay attention in IDG 14. “Talk to not at” 15. Address Medicare regulations and discuss with IDG 16. Frequently acknowledges a job well done 17. Concern for staff safety in field Marketing Response Near identical to previous with exception of the following 1. Eager to educate 2. Actively engaged by promoting hospice in community 3. Name recognition connected to hospice agency 4. Peer to peer education with other physicians Administrative Response to Questionnaire Know LCD guidelines Know regulations: F2F Certification periods Narrative MD visit note: new regulations, what is related/unrelated to hospice Continued Admin Response Medication management, cost-containment IDG: Team goals for future Ensuring nurse documentation matches MD Review medication in IDG HDM Community Education From the single conversation to the Meeting Hall…. What is POLST? Physician Orders for Life Sustaining Treatment POLST Success Comfort Measures Only 11,836 Full Treatment 1,153 Hospital Death 6.4% Hospital Death 44.2% Out Hospital Death 55.8% 58,000 deaths reviewed, 31% had POLST in Oregon Registry Patient treatment choices honored, including avoiding dying in hospital Limited Interventions 4,787 Oregon Study: Location of Death and POLST Orders Hospital Death 22.4% Out Hospital Death 77.6% Fromme EK, JAGS 2014 Out Hospital Death 93.6% POLST vs. Advance Healthcare Directive POLST For seriously ill/frail, at any age Physician orders for medical treatment AHCD For anyone 18 and older General instructions for treatment Appoints decisionmaker California POLST Project Translating an individual’s wishes for care during serious or chronic illness into medical orders that honor those preferences for medical treatment. POLST Conversation A rich conversation with each individual patient Community Collaboration Consistent Form Integrating POLST into the community standard of care Standardized form recognized across care settings Comprehensive Education To promote excellent conversational skills with patients and families HMD- Patients and Psychosis Breath of education requirement of the HMD Rate of elderly patients with psychotic symptoms 25 The elderly currently account for about 12% of the US population, but that figure is expected to rise to 20% by the year 2030.[3] http://www.medscape.com/viewarticle/564899_2 Jessica Broadway, Jacobo Mintzer DisclosuresCurr Opin Psychiatry. 2007;20(6):551558. 26 Prevalence of Psychosis in Elderly Persons Community: 0.2% to 4.7%; In NYC study (Cohen et al, 2004): 3% psychosis (7% Blacks vs 2% Whites), but if include paranoid ideation: 14 % of sample. Age 85+ (without dementia): 7.1% to 13.7%. May be prodromal for dementia Age 95+(without dementia): 7.4% Nursing Homes: 10% to 62% Geriatric Psychiatry In-Patient Units: 10% late onset psychosis--¾ are women, 40% due to AD or VaD 27 Etiologies of Psychoses in Older Adults (order of frequency) 1. Alzheimer’s disease and other dementias (40%) 2. Depressive disorder (33%) 3. Medical/toxic causes including substances (11%) 4. Delirium (7%) 5. Bipolar Affective Disorder (5%) 6. Delusional disorder (2%) 7. Schizophrenia spectrum disorders (1%) Manepalli et al, 2007 and Webster et al, 1998 28 Problems with prescribed meds http://www.npr.org/player/v2/mediaPlayer.html?action=1&t=1&islist=false&id =5033873&m=5033874 Two Preliminary Points In older adults, for all conditions: think “Comorbidity” Any new psychiatric conditions or change in symptoms: Must assume physical cause until proven otherwise 30 Lifetime Risk (1 in 4 lifetime risk) Up to 23% of the older adult population will experience psychotic symptoms at some time, with dementia being the main contributing cause (Khouzam & Emes, 2007). 31 Delirium 1. Perceptual disturbances are common; however, hallucinations also are frequent: Hallucinations: 40% to 67% Delusions: 25% to 50% 2. Psychotic symptoms are more commonly seen with hyperactive rather than hypoactive delirium 3. Visual > > auditory> other hallucinations 4. Paranoid delusions are the most common delusions 5. Clinical evaluation should help identify; dementia and delirium are often related 32 Alzheimer’s Disease 1. Prevalence of psychotic symptoms: 16% to 70%; Median: 37% for delusions; 4% to 76% (Median 23%) for hallucinations 2. Rates of psychoses: about 20% in early stages to 50% by third or fourth years of illness (Overall: 30% to 50%). 3. Most common in middle stages. 4. Hallucinations: visual> auditory> other 5. Hallucinations most commonly people from past, e.g., deceased relatives, intruders, animals, objects. 6. Delusions: most common are false beliefs of theft, infidelity of one’s spouse, abandonment, house not one’s home, and persecution. Decreases in later stages. 33 Vascular Dementia Cache County study found prevalence of hallucinations similar between AD and VaD, but delusions were higher in AD (23% vs 8%). HDM Impetrative to understand complexity of disease relevant to demographic: Disproportionate risk? HMD to be study savvy Example: CATIE study (Clinical Antipsychotic Trials of Intervention Effectiveness) 35 Alzheimer’s Disease CATIE study, in which time to discontinuation did not differentiate antipsychotic medications from placebo, and black box warnings regarding higher mortality rates, suggests that medications must be used judiciously. In CATIE study, the median time to the discontinuation of treatment due to a lack of efficacy favored olanzapine and risperidone, but the time to the discontinuation of treatment due to adverse events or intolerability favored placebo. Mean doses used in CATIE trial: risperidone(1mg), olanzepine (5.5mg) , and quetiapine (56.5mg). Recommended doses: Risperidone:0.75mg to 1.5mg Olanzepine: 2.5mg to 7.5mg Quetiapine : 25mg to 200mg Psychosocial modalities: Sensory enhancement, structured activities, social contact, behavior therapy. The Older Adult Brain As people age, they usually experience slower information processing and mild memory impairment. Older brains frequently decrease in volume and some nerve cells, or neurons, are lost as aging occurs. What is Normal Or To Be Expected? Common age-related cognitive decline is often slower information processing and mild memory loss. Mild cognitive impairment. Some people develop cognitive and memory problems that are not severe enough to be diagnosed as dementia but are more pronounced than the cognitive changes associated with normal aging. Many patients with this condition later develop dementia, some do not. Depression. People with depression are frequently passive or unresponsive, and they may appear slow, confused, or forgetful. Delirium is confusion and rapidly altering mental states and sometimes disoriented, drowsy, or incoherent. Delirium is usually caused by a treatable physical or psychiatric illness, such as poisoning or infections. Patients with delirium often make a full recovery after treated. Reasons for Memory Loss Normal Brain Aging Process Damage Trauma Medications Drugs Abuse Alcohol Abuse • • • • • • Small Strokes Depression Toxic Chemicals Too Much Thyroid Infections Disease Normal Aging Process As we age, our brains frequently decrease in volume and some nerve cells, or neurons are lost. Medications Medication can also affect memory. Alcohol and Drug Abuse Alcohol and drugs impairs memory and can result in acute and/or chronic cognitive deficits. Small Strokes During a stroke, blockage of blood to the brain can occur. Lack of blood flow in the brain can result in memory loss. Depression Depression is a condition marked by memory loss. The signs and symptoms can be similar to dementia. Depression is more common in older people who have dementia, especially Alzheimer’s. Disease Symptoms that include decreased intellectual functioning that interferes with normal life is dementia. Types of Dementia Alzheimer's Disease Vascular Dementia Lewy Body Dementia Frontotemporal Dementia HIV-associated Dementia Huntington's Disease Dementia Pugilistica Corticobasal Degeneration Creutzfeldt-Jakob Disease The Caregiver’s Role Help maximize the patient’s independence Assists with the tasks the patient can no longer do Set up activities, such as leaving notes around the home as reminders, to aid memory retention Educate self on the disease process and side effects the patient may experience A caregiver must be patient with a loved one experiencing memory loss and accept help from others Caregivers must take time for themselves for physical exercise and relaxation each day HDM responsibility: to share resources to both clinical staff, patients, and families Online Apps and Game Resources 1. Lumosity: Online and mobile app game center 2. Merriam-Webster Encyclopedia Website: 3. AARP http://www.aarp.org/health/brain-health/brain_games.html 4. Games for t he Brain http://www.gamesforthebrain.com/ Delivering bad news HMD should be an expert in the nuance of delivering bad news, including teaching future doctors the same skill HDM- Local Medical Education To deliver bad news, complex understanding of disease trajectory is a must… You have to know how you got there… Setting a template for understanding disease trajectories‘ Curative Restorative Palliative Bereavement EMPATHY …. IS THE HIGHWAY TO FACILITATE HEALING.. …cure sometimes relieve often comfort always. HDM-Policy Details An attempt to control the chaos HMD At Work Know the Rules And what they morph into CMS FY 2014 Rule • • Reinforced that all providers should code and report the principal diagnosis as well as all coexisting and additional diagnoses related to the terminal condition or related conditions. Clarified the use of nonspecific, symptom diagnosesRef: FY 2014 Hospice Wage Index and Payment Rate Update; Hospice Quality Reporting Requirements; and Updates on Payment Reform [CMS-1449-P] CMS Changes Related to Coding • Codes under the classification, “Symptoms, Signs, and Illdefined Conditions” (ICD-9 780-799) are not to be used as a principal diagnosis; however, they may be used as other, additional, or coexisting in the additional diagnoses lines on the claims form. o • Includes “Debility unspecified” (ICD-9 799.3) & “Adult Failure to Thrive” (ICD-9 783.4) Effective date: October 2014 Changing Regulatory Climate Why did this CMS take this action • In FY 2012, both “debility” and “adult failure to thrive” were in the top five hospice diagnoses reported on claims o • • first and third most common hospice diagnoses, respectively. Trending upward over the past decade “Vascular Dementia” “Traps Encoding” A new go to ICD may be as inaccurate as the old even though allows for billing revenue IE CHF The Changing Regulatory Climate Cont’d What industry experts are saying: • • • CMS equates debility with hospices enrolling chronically ill patients requiring custodial care who are not terminally ill Debility patients typically have longer LOS CMS trying to reign in hospice expenditures... Additional Clarifications: Diagnosis Reporting on Hospice Claims • “All of a patient’s coexisting or additional diagnoses” related to the terminal illness or related conditions should be reported on the hospice claims Federal Register/ Vol. 77, No. 145/ Friday July 27, 2012 Diagnosis Reporting: CMS’ Position... • • • • Hospice patients at the end-of-life are elderly and likely have multiple co-morbidities. Claims that report only one diagnosis are “not providing an accurate description of the patients’ conditions.” After doing a comprehensive assessment “providers should code and report coexisting or additional diagnoses to more fully describe the Medicare patients they are treating.” Will provide data needed for hospice payment reform. ICD-9-CM Guidelines for Coding and Reporting • • • Requires reporting of all additional or co-existing diagnoses. Adherence to these guidelines when assigning ICD-9-CM diagnosis and procedure codes is required under HIPAA Imperative that hospice providers follow ICD-9 coding guidelines and sequencing rules for all diagnoses. Implications for Coverage Are hospice agencies responsible for all of the care, medications, and equipment for all of the diagnoses listed on the claim form? YES Implications for Coverage cont’d CMS reiterated what was stated in the original Conditions of Participation (1983): ...“hospices are required to provide virtually all of the care that is needed by terminally ill patients”. (48 FR 56010-56011). CMS states “Therefore, unless there is clear evidence that a condition is unrelated to the terminal prognosis, all services would be considered related. It is also the responsibility of the hospice physician to document why a patient's medical need(s) would be unrelated to the to the terminal prognosis. ...determination of what is related versus unrelated to the terminal prognosis remains within the clinical expertise and judgement of the hospice medical director in collaboration with the IDG.” HDM is responsible for directly stating unrelated diagnosis and treatment Diagnosis Reporting Requirements On Claim Form • • • List the primary hospice diagnosis List all related “other” diagnoses Do not list unrelated co-morbidities o But be sure to list them in the clinical record • The hospice claim includes a field for the patient’s principal hospice diagnosis, and allows for up to 17 additional diagnoses on the paper UB-04 claim, and up to 24 additional diagnoses on the 837I 5010 electronic claim Individual Primary Dementia Codes Individual Primary Dementia Codes contd. ICD-9 Dementia Fact Sheet How to recognize a manifestation code when you see one…. Does the condition have an underlying etiology? Dose the Note in the ICD-9 book state “code first”? Is “in disease classified elsewhere” in the code title? If the answer to any of these is “yes”, the condition/code is probably a manifestation code. “In diseases classified elsewhere” codes are never permitted to be used as first listed or principal diagnosis codes. They must be used in conjunction with an underlying condition code and they must be listed following underlying condition In these cases, code the etiology (the cause) first, followed by the manifestation. Do NOT use the manifestation code as the principal diagnosis. Case Study Initial certification narrative: 84yr old F w mild COPD, mild dementia. On recent CXR, she was found to have an enlarging lung mass for which w/u was declined. She has had increased weakness, decreased appetite with weight loss in 3 months from 130 to 125 lbs, and 1 episode of hemoptysis, all attributed to presumptive lung CA. Patient recently seen by primary care MD who noted weight loss, risk for sudden decline, and her belief that more likely than not that patient will have terminal event in the next 6 months… (narrative continued on next slide). Case Study cont’d Initial certification narrative cont’d: Pt is DNR/DNH/CMO, clear in her wish for no interventions to prolong her life. Given this patient’s clinical decline, likely lung cancer, weight loss, episodes of hemoptysis, and wish for DNR/CMO, pt is a high risk for massive hemoptysis, respiratory failure, rapid decline. It is my professional judgement that prognosis is less than 6 months. • What is the current nature of her decline? o • No further hemoptysis, has lost 4 lbs, and has had very slightly increased weakness. No new symptoms have arisen. Do you believe it is more likely than not that she will have a terminal event in the next 6 months? o Nothing to suggest a terminal decline... Case Study cont’d • • • Can use “at high risk of life-threatening hemoptysis and respiratory failure” when enrolling this patient, but if these do not occur, cannot keep using them for recertification. Clinical record needs to demonstrate downward trajectory. If none exists, patient is no longer eligible for the hospice benefit. Coding “Suspected Cancer” • • • 799.3 Unspecified debility (use this 2nd) 784.2 Swelling, mass, or lump in chest (use this 1st) 793 Nonspecific abnormal findings on radiological and other exam of body structure. Instructional notes: “...(780-799)~this section includes symptoms, signs, abnormal results of laboratory or other investigative procedures, and ill-defined conditions regarding which no diagnosis classifiable elsewhere is recorded.~ The conditions and signs or symptoms included in categories 780-796 consist of : (a) cases for which no more specific diagnosis can be made even after all facts bearing on the case have been investigated; (b) signs or symptoms existing at the time of initial encounter that proved to be transient and whose causes could not be determined; (c) provisional diagnoses in a patient who failed to return for further investigation or care; (d) cases referred elsewhere for investigation or treatment before the diagnosis was made; (e) cases in which a more precise diagnosis was not available for any other reason;...” Certification of Terminal Illness (CTI) when the Diagnosis Changes • • A new CTI is not required because the principal diagnosis changes, nor do benefit periods or election status change Physician documentation (including IDG documentation) should include: o New terminal diagnosis and why it changed o Why it is causing a 6 month or less prognosis o Evidence of prognostic indicators o Reference to outcomes of symptom assessment scales as applicable What if you can’t determine a single hospice diagnosis? CMS… • • • States that they expect hospice providers will not discharge beneficiaries who meet eligibility requirements, even if they can’t determine a single principal diagnosis. Recommends listing all related diagnoses, picking the predominant one as the terminal dx If the patient meets the eligibility requirements, they will have access to hospice services under the Medicare Hospice Benefit. Summary • • • • • As of October 1, 2014, failure to thrive or debility can no longer be used as a primary diagnosis. Select a diagnosis from the patient’s list of comorbid conditions and document the effects of other significant co-morbids to support eligibility. Discharge patient if they no longer meet eligibility requirements and monitor disease trajectories. Ensure that your HMD documents why a condition is not related. Ensure that your hospice has ICD-9/ICD-10 coding expertise Biomarkers used to support Prognostication In addition to Prognostic indicators LCDs (Local Coverage Determinations) and other tools General used to support frailty, debility (ill defined diagnosis) • • • • • • • BMI < 21 5% wt loss < 6 months Albumin < 3.5 mg/dl Anemia High CRP Cholesterol < 150 mg/dl Low Lymphocytes References Zakai, Neil MD, et al, A Prospective Study of Anemia States, Hemogloblin Concentration, and Mortality in an Elderly Cohort, 2005, Arch Int Med, pp 2214-19 Harris, Tamara, B, MD, MS et al, Association of Interleukin6 and C-Reactive Protein Levels with Mortality in the Elderly, 1999, Am J Med, vol. 106, pp 506-12 Herman MD, MPH, Francois, et al,Serum Albumin Levels on Admission as a Predictor of Death, Length of Stay, and Readmission, 1992, Jan, Arch Intern Med, Vol 152, 125-130 Rudman, Daniel, MD, et al, Relationship of Serum Albumin Concentration to Death Rate in Nursing Home Men, 1987 Journal of enteral and Parenteral Nutrition, vol 11, pp 360-63 Verdery, Rob B, et al, “Hypocholesterolemia as a Predictor of Death; A Prospective Study of 224 Nursing Home Residents,” 1991, Journal of Gerontology, Vol 46,(3), pp M84-M90 Noel, Margaret A MD, et al, “Characteristics and Outcomes of Hospitalized Older Patients Who Develop Hypocholesterolemia,” JAGS, VOL 39, pp455-61 Cardiac Disease • Hyponatremia • Cr (> 2) - some studies >1.4 • BNP > 480 pg/dl ( 42% 6 mo mortality) • Troponin • BUN > 30 • CRP • Seattle Heart Model • EFFECT Model References Palliation in heart failure, Davis, AJHPM 2005: 22, 211 Fast Fact Concept #143 NEJM - 5/2008 Zetheilius Biomarkers in Heart Failure, NEJM, Vol 358; 2148-2159 Bonnie et al., Circ. Heart Fail. 2012; 5: 183-190 JAMA 2OO3: 290(19): 2581-2587 Am J Cardiol 2006; 98:1076-1093 Maisel, B-Type Natriuretic Peptide Levels: Diagnostic and Prognostic in Congestive Heart Failure , Circulation, 2002, 105;2328-2331 Pulmonary Disease • BODE • CRP • Fibrinogen • High WBC count References Respiratory Care January 2004, 48 (1) 90-98 Am J Respir Crit Care Med. 2012 May 15;185(10):1065-72. dol: 10.1164/rccm.201110-1792OC. Epub 2012 Mar 15. Inflammatory biomarkers improve clinical prediction of mortality in chronic obstructive pulmonary disease. Thorax 2008;63;665-666 community acquired pneumonia CHEST 2010; 138(3):559-567 ARDS Crit C Med. 2008;36(7):2061-2069 ICU ventilation N Engl J Med 2010;363:266-74. Pulm embolism Am J Respir Crit Care Med Vol 182. pp 1178-1183, 2010 Pulm embolism Dementia Mortality Risk Index • • MRI - Mitchell, JAMA 2004: 291:2734-2740 Coexisting Fracture or Pneumonia - Morrison RS JAMA 2000; 264:47-52 Liver Disease • • MELD score - INR, Bilirubin, CR Sodium - (hepatocellular carcinoma-use MELD- Na score) References Kamath, Hepatology 2001 Feb 33; A464-70 A model to predict survival in patients with end-stage liver disease Renal Disease • Albumin < 3.5 • BNP, NT - Pro BNP, Troponin, CRP References Friedman, JACN JASN February 1, 2010 vol. 21 2 223-230 Reassessment of Albumin as a Nutritional Marker in Kidney Disease Fast Fact #191 Chaykovska L, Clin. Lab. 2011;57:455-467 Biomarkers for the prediction of mortality and morbidity in patients with renal replacement therapy. Cohen, J Palliat Med. 2006;996):977-992. Predicting Six-Month Mortality for Patients Who Are on Maintenance Hemodialysis Stroke • BNP, CRP References LaBorde Expert Rev Proteomics. 2012;9(4):437-449. Potential Blood Biomarkers for Stroke JAMA 2007’297 Mitka Hemorrhagic stoke guidelines issued Stroke 2008;39:2304-2309 Sacco et al, Stroke 2009;40:394 HIV and HAART References http://www.art-cohort-collaboration.org Other Resources Pallipedia.org http://www.eprognosis.org http://www.victoriahospice.org/health-professionals/clinicaltools# Sobering Data • • • • Malignant Hypercalcemia 8 weeks Malignant Pericardial Effusion 8 to 12 weeks Carcinomatous Meningitis 8 to 12 weeks Multiple Brain Mets o Without XRT 4 to 8 weeks o With XRT 12 to 24 weeks “Predication is very difficult, especially if it is about the future” Niels Bohr CHF - Prognostic Variables • NYHA Functional Classification o -Class I - 5% to 10% mortality per year o -Class IV - 40% to 50% mortality per year • Recent cardiac hospitalization • Elevated BUN • Systolic BP < 100 under/or pulse > 100 • Decreased LVEF CHF - Prognostic Variables • Ventricular Dysrhythmias • Anemia • Hyponatremia • Cachexia • Reduced functional capacity • Co-morbidities (DM, COPD, CVA etc.) Frailty as an Accumulation of Deficits • • • • • The Frailty Index Number of Deficits divided by the number of deficits considered Numerical value between 0 and 1 Strongly correlated with the risk of death If > 0.5 - close to 100% mortality at 6 months Rockwood K, Miniski A Mech Aging Dev 2006;127; 494-496 Rockwood K et al, J Am Geriatr Soc 2010; 58:316-323 Clinical Frailty Index 1. Very Fit 2. Well 3. Well with treated comorbid disease 4. Apparently vulnerable - “Slowed Up” 5. Mildly frail - Limited dependence 6. Moderately Frail - Help with all ADL’s 7. Severely Frail - Completely dependent upon others GeriPal - www.eprognosis.org …. Good resource… Final considerations... • Prognostication is a critical skill for physicians • Our ability to prognosticate accurately is limited, especially with organ system failure and frailty AAHPM Reference too box website Table of contents Link Face to Face On July 16, 2010, CMS posted a proposed rule for Section 3132 of the new health care reform law, the Affordable Care Act (ACA), which requires a hospice physician or nurse practitioner to have a face-to-face encounter with each hospice patient before their 180-day recertification and for each 60-day recertification period after that date. This new statutory requirement will better enable hospices to comply with hospice eligibility criteria, and to identify and discharge patients who do not meet those criteria. Face to Face Encounter Update: CMS has issued CR7337 to include exceptional circumstances for the face to face encounter requirement for new hospice admissions in the third or later benefit period. In cases where a hospice newly admits a patient who is in the third or later benefit period, exceptional circumstances may prevent a face-to-face encounter from being conducted prior to the start of the benefit period. Requirements: New hospice admission Third or later benefit period Exceptional circumstance Timing: ONLY if the above requirements are met and documented: Face to face encounter which occurs within 2 days after admission will be considered timely. If the patient dies within 2 days of admission without a face to face encounter, the encounter will be deemed complete. Examples (as provided by CMS): The patient is an emergency weekend admission and it may be impossible for a hospice physician or NP to see the patient until the following Monday, or CMS data systems are unavailable and the hospice may be unaware that the patient is in the third benefit period, or Other exceptional circumstances as documented by the hospice. Documentation requirements: Documentation will be required for the exceptional circumstance that prevented the face to face encounter from being conducted in a timely way.