P2e Reorientation

Recent discussion with our MDS coordinator about P2e. Does this need to be a formal reorientation program, or does it include cues as to meals, invites to activities, the cues that we give every day re: season, day of week, time of day, etc. I was under the impression that it included all the little cueing that we do QD, she now says it has to be a formal program.

Next question, if it's care planned: Staff give cues for reorientation PRN. It should count shouldn't it? I know it's not a payer question, but I would like to be coding accurately.