Wiki Advance Care Planning

[MHare64]

I work for a Hospice and Palliative Care organization, and I have a APRN who consistently bills for ACP along with E/M visits, which is fine, but I really question whether she is meeting the requirements for ACP.
I have provided the following information, and she does sometimes document the information, but the way she documents really has me questioning the use of ACP code.
Information provided is:

• The voluntary nature of the visit;
• The explanation of advance care directives;
• All participants present during the discussion;
• The time spent discussing ACP during the face-to-face encounter; and
• Any changes in health status or healthcare wishes if the patient becomes unable to make their own decision.

Time wise she meets the requirements for ACP, she does document who is present during the discussion, and that the discussion is voluntary. Where I questions is she documents that the discussion is about the differences between Palliative care and Hospice care and what those two programs would look like for the patient. I don't ever see anything about advance directives, other than she might leave the paperwork with the patient and have the social worker follow up with them, or to say that the patient already has an advance directive and or DNR. Is this enough to meet the requirement for ACP?
Thank you in advance for any advice that I may offer my providers.