Beyond the basics

IRMAA questions

What is IRMAA?

IRMAA stands for Income-Related Monthly Adjustment Amount. It is an extra amount some people pay in addition to their Medicare Part B and Part D premiums when their income is above certain limits.

Social Security generally uses federal tax information from two years earlier to determine whether your client owes IRMAA. The amount is set for a particular calendar year; SSA reviews income information each year, so a client's IRMAA may change from one year to the next.

There are different income brackets, and the surcharge depends on your client's modified adjusted gross income and tax filing status. The brackets and premium amounts can change each year. See Social Security’s current Medicare premium and IRMAA information for current figures.

Does my client's type of Medicare coverage affect whether they pay IRMAA?

IRMAA is based on income, not on whether your client has Original Medicare, Original Medicare with a Medigap policy, or a Medicare Advantage plan. If they have Medicare Part B, an income-related adjustment may apply to their Part B premium regardless of which of these coverage options they choose. Medigap and Medicare Advantage do not exempt a client from Part B IRMAA.

IRMAA may also apply to your client's Part D prescription drug coverage. If they have Part D—including drug coverage through a Medicare Advantage plan—they may owe a separate Part D IRMAA in addition to their plan’s premium. The amount depends on their income and tax filing status.

What counts as income for IRMAA?

SSA generally uses modified adjusted gross income (MAGI) from your client's federal tax return. For IRMAA, MAGI generally means adjusted gross income plus tax-exempt interest. Check their notice and the tax return for the year SSA used if the amount looks unfamiliar. The information SSA received could be incorrect. If so, you can request a new initial determination and provide the correct tax return or tax transcript filed with the IRS.

How can my client obtain a copy of their IRS Tax Transcript?

The fastest way is through your client's IRS Individual Online Account. Have them sign in, open “Tax Records,” then choose the transcripts link to view, download, or print available transcripts.

If your client cannot access their online account, you can request a transcript by mail on their behalf; it is generally delivered within 5 to 10 calendar days to the address on their latest tax return. You can also call the IRS automated transcript line at 800-908-9946. See the IRS page on getting a tax transcript for details and other options.

Does retiring automatically remove my client's IRMAA?

No. IRMAA does not automatically change just because a client retires or their income goes down. Retirement or stopping work may be a qualifying life-changing event for an SSA-44 request when it causes a reduction in income, but SSA will not automatically apply a reduced rate when a client retires. An official request must be filed on their behalf. SSA will review the request and supporting evidence and make a decision.

Can a one-time income spike, such as a Roth conversion, affect IRMAA?

It can. IRMAA is based on tax-return MAGI, not only wages or recurring income. A Roth conversion is taxed as ordinary income in the year it happens, which flows into adjusted gross income and is part of MAGI — the same is true of taxable capital gains or other one-time taxable events. If your client's income in a later year falls, that lower income alone may not qualify for an SSA-44 request. They must have experienced what SSA refers to as a life-changing event.

Why is Social Security using an older tax return?

IRMAA is generally calculated using federal tax information from two years earlier. Because tax returns may be filed on extension and IRS information may not be available to SSA when it makes a determination, SSA may use an earlier return if the return from two years earlier is not available. Check the client's notice to see which tax year SSA used.

If the information is wrong, outdated, or has since been corrected—or if your client filed Married Filing Separately and lived apart from their spouse for the entire year—IRMAAssist can walk you through requesting a new initial determination.

If your client experienced a life-changing event after the tax year SSA used and it reduced their income, you can ask SSA to reconsider their IRMAA using Form SSA-44.

What if my client filed an amended tax return?

If an amended return changes the income SSA used, ask SSA how to request a new initial determination using the corrected information. This is different from asking for reconsideration because of a life-changing event, and Form SSA-44 may not be the right request. Keep a copy of the amended return and any IRS notice showing it was processed.

What if my client's income ends up higher than expected next year?

SSA’s POMS says an income estimate may be updated as often as necessary. However, SSA will not accept an updated estimate that could raise the client's IRMAA above the amount SSA originally imposed using IRS tax data for that year. This restriction applies to estimates; POMS says it does not apply to amended returns or corrected tax information.

If an estimate was given to SSA, the agency asks for a signed copy of the tax return once it's filed. If your client's circumstances change or their filed return differs from the estimate, contact SSA and ask how the new information affects their case. See SSA POMS HI 01120.065, Estimates of MAGI.

What if my client's income dropped for a reason that is not listed on Form SSA-44?

A lower income by itself may not be enough for an SSA-44 reconsideration. The form lists specific life-changing events, such as marriage, divorce, a spouse’s death, stopping or reducing work, certain losses of income-producing property or pension income, and an employer settlement payment. If your client's situation is not listed, they may not qualify for an SSA-44 appeal. Contact SSA to ask whether another review option may apply.

What if my client missed the reconsideration deadline?

SSA’s standard reconsideration period is 60 days after the notice is received. SSA generally assumes it was received five days after the date printed on the notice, unless it can be shown that it arrived later. A written request for more time, explaining why the deadline was missed, can be submitted to SSA; SSA decides whether there is good cause to extend it. Contact SSA promptly for the best possible outcome.

How does my client submit their request?

SSA generally accepts these requests in person, by phone, by fax, or online through a personal my Social Security account — though online filing isn't available for every request type or circumstance. On the "Print and Submit" step at the end of the wizard, choose the method your client plans to use; IRMAAssist generates method-specific instructions alongside the summary and evidence checklist, ready to print or save.

Whichever method is used, confirm with SSA that the request and supporting evidence were received, and keep a copy of everything submitted along with the confirmation.

Does IRMAAssist decide whether SSA will approve my client's request?

No. The tool provides an estimate and helps you prepare the appeal. It cannot guarantee that a request qualifies or will be approved. SSA reviews the facts, evidence, and applicable rules and makes the final determination.

Official information