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Hospice documentation guide

End-Stage Pulmonary Disease (COPD/ILD)

ICD-10: J44.x / J84.x

LCD L34538 Eligibility Criteria

Part II required for all diagnoses:PPS <70 AND dependence in 2+ ADLs. These apply in addition to diagnosis-specific criteria below.
  • 1Criterion 1 (must meet ONE of): (a) dyspnea at rest, OR (b) two or more ER visits or hospitalizations in prior 12 months for COPD/ILD exacerbation
  • 2Criterion 2 (required separately): SpO2 ≤88% on room air, OR pCO2 ≥50 mmHg, OR RN attestation of oxygen dependency where measurement is unsafe
  • 3PPS below 70
  • 4Dependence in 2+ ADLs

Charting Tips for Audit Defense

  • Criterion 1 is an OR — dyspnea alone is sufficient; ER visits alone are sufficient
  • Criterion 2 is always separately required — meet Criterion 1 AND Criterion 2
  • Record SpO2 at rest on room air at every visit: 'SpO2 84% at rest, RA'
  • If patient can't safely remove O2 to measure: document RN attestation of O2 dependency
  • List ER visits and hospitalizations by date and discharge diagnosis

Common Documentation Mistakes

Treating Criterion 1 as requiring BOTH dyspnea AND hospitalizations — it's an OR
Documenting SpO2 on oxygen, not room air — criterion requires RA measurement
Forgetting Criterion 2 when Criterion 1 is met — both are required
Not documenting oxygen use: LPM, nasal cannula vs mask, hours per day
Failing to note that COPD is 'end-stage' vs just severe

Sample Note Findings (LCD-Aligned)

These examples show the level of specificity needed to survive ADR review. Generic language will not suffice.

Criterion 1a met: dyspnea at rest. Patient unable to complete a sentence without stopping to breathe. Pursed lip breathing observed. RR 26 at rest.
Criterion 2 met: SpO2 84% on room air at rest. Patient supplemented to SpO2 93% on 4L NC. Cannot safely discontinue O2 for measurement per RN assessment.
Two hospitalizations for COPD exacerbation: 02/04/2026 (3-day admission) and 04/15/2026 (5-day admission). Discharged on oral steroids and increased O2.
On home O2: 4L NC at rest, 6L NC with any exertion. Uses concentrator 22+ hours daily.
PPS 40: mainly in bed >50% of day, unable to do most activities, requires assistance with most self-care, intake reduced.

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