Medicare and a Never-Event Involving a Patient Transfer Case

A Medicare patient is admitted from a skilled nursing facility for dehydration. There is a close clinical relationship between the facilities, with admissions and services at both facilities referred to each other. A day or two after admission, a pressure ulcer is assessed. There is concern at the hospital about whether they will be paid for this condition.
The hospital staff claims that the pressure sore was caused by the local skilled nursing facility. The skilled nursing facility did not document any skin issues prior to discharge and believes the hospital is blaming it for the hospital’s poor skin care.
As an administrator in this hospital, you would naturally want to get reimbursed for the care now required to treat this patient’s pressure ulcer, to prevent this kind of issue from happening in the future, and also to maintain good organizational ties with this skilled nursing facility.
What does administration need to do to ensure that the hospital is not submitting claims for services for which payment is not available under applicable rules? Take into account the role of individuals who may want to become a whistleblower, or qui tam relator, under the False Claims Act.

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