Objective: Pressure ulcers (PU) are considered harmful conditions that are reasonably prevented if accepted standards of care are followed. They became subject to the payment adjustment for hospital-acquired conditions (HACs) beginning October 1, 2008. We examined several aspects of the accuracy of coding for pressure ulcers under the Medicare Hospital-Acquired Condition Present on Admission (HAC–POA) Program. We used the “4010” claim format as a basis of reference to show some of the issues of the old format, such as the underreporting of pressure ulcer stages on pressure ulcer claims and how the underreporting varied by hospital characteristics. We then used the rate of Stage III and IV pressure ulcer HACs reported in the Hospital Cost and Utilization Project State Inpatient Databases data to look at the sensitivity of PU HAC–POA coding to the number of diagnosis fields. Methods: We examined Medicare claims data for FYs 2009 and 2010 to examine the degree that the presence of stage codes were underreported on pressure ulcer claims. We selected all claims with a secondary diagnosis code of pressure ulcer site (ICD-9 diagnosis codes 707.00–707.09) that were not reported as POA (POA of “N” or “U”). We then created a binary indicator for the presence of any pressure ulcer stage diagnosis code. We examine the percentage of claims with a diagnosis of a pressure ulcer site code with no accompanying pressure ulcer stage code. Results: Our results point to underreporting of PU stages under the “4010” format and that the reporting of stage codes varied across hospital type and location. Further, our results indicate that under the “5010” format, a higher number of pressure ulcer HACs can be expected to be reported and we should expect to encounter a larger percentage of pressure ulcers incorrectly coded as POA under the new format. Conclusions: The combination of the capture of 25 diagnosis codes under the new “5010” format and the change from ICD-9 to ICD-10 will likely alleviate the observed underreporting of pressure ulcer HACs. However, as long as coding guidelines direct that Stage III and IV pressure ulcers be coded as POA, if a lower stage pressure ulcer was POA and progressed to a higher stage pressure ulcer during the admission, the acquisition of Stage III and IV pressure ulcers in the hospital will be underreported.