IRMAA Appeal: How to Challenge Your Medicare Premium Determination

Medicare Premium Surcharge: The IRMAA Surprise

You open your mail and there it is, a notice from Social Security telling you that your Medicare premiums are going up. Way up. You're being hit with IRMAA, and suddenly retirement feels a bit more expensive than you planned.

Here's the good news: that determination isn't necessarily final. In my practice, I see clients who don't realize they have legitimate grounds to appeal. Let's walk through when and how you might challenge that higher premium.

What Exactly Is IRMAA?

IRMAA stands for Income-Related Monthly Adjustment Amount. It's essentially a surcharge on Medicare Part B and Part D premiums for higher-income beneficiaries. Social Security looks at your modified adjusted gross income (MAGI) from two years prior, so your 2024 tax return determines your 2026 premiums.

The problem? A lot can change in two years. Maybe you retired. Perhaps you sold a business or experienced a significant life event. Social Security doesn't automatically know about these changes, which is where the appeal process comes in.

Life-Changing Events That Qualify for an Appeal

The Social Security Administration recognizes specific circumstances that may warrant a fresh look at your IRMAA determination. These are called Life-Changing Events, and they include:

• Marriage: Combined income may look different now

• Divorce or annulment: Your filing status and income have changed

• Death of a spouse: Household income is significantly different

• Work stoppage: You or your spouse retired or reduced work hours

• Work reduction: Part-time status or reduced income

• Loss of income-producing property: Due to disaster, fraud, or other circumstances beyond your control

• Loss of pension income: Employer pension terminated or reduced

Notice what's not on this list: investment losses, poor market performance, or simply having less money than before. The qualifying events are specific, so it's important to know whether your situation actually fits.

How the Appeal Process Works

If you believe you qualify, you'll need to complete Form SSA-44.  This form asks you to identify which life-changing event occurred and provide documentation.

Here's what to expect:

1. Gather your evidence: This might include a letter from your former employer, divorce decree, death certificate, or prior tax returns and so on.

2. Complete Form SSA-44: Be thorough and accurate

3. Submit to Social Security: You can mail it, visit your local office, or file online at ssa.gov

4. Wait for a decision: Processing times vary, but you should receive a written response

One thing I remind clients: you're asking Social Security to use more recent income information instead of that two-year-old tax return. You'll need to provide an estimate of your current or expected income, so be prepared with realistic numbers.

What If Your Appeal Is Denied?

Don't panic. You have the right to request reconsideration. The appeals process has multiple levels, if needed, though most straightforward cases get resolved early.

That said, if your situation doesn't fit one of the qualifying life-changing events, an appeal likely won't succeed. Sometimes the income spike was a one-time event—like a Roth conversion or selling appreciated stock—and there's no appeal remedy for that. This is where proactive financial planning becomes so valuable.

Planning Ahead to Avoid IRMAA Surprises

The best IRMAA strategy is often prevention. Since premiums are based on income from two years prior, retirement income decisions you make today could affect your Medicare costs down the road.

Consider how these might impact your future IRMAA bracket:

• Large Roth conversions: Great for long-term tax planning, but they spike current income

• Selling a business or property: Capital gains count toward MAGI

• Taking bigger retirement distributions: Required minimum distributions can push you into higher brackets

Sometimes the financial decisions that feel urgent in the moment benefit from a more measured approach. IRMAA planning is similar. Thinking two to three years ahead can save you significant money.

Key Takeaways

• IRMAA isn't always final—qualifying life events may warrant an appeal

• Form SSA-44 is your tool for requesting a new determination

• Documentation matters—be prepared to prove your life-changing event

• Proactive planning can help you avoid IRMAA surprises before they happen

• Not all income drops qualify—investment losses and market downturns don't count
  

Let's Talk About Your Situation

IRMAA can feel like a penalty for doing well financially, but understanding the rules and knowing when you can appeal gives you more control. If you're facing an IRMAA determination and wondering whether an appeal makes sense, or if you'd like to plan ahead to minimize future Medicare costs, I'd love to see if we can help.

Book a complimentary consultation and let's figure out the best path forward for your retirement.

Disclosure: Arc Element Wealth Design is a Nebraska-registered investment adviser. This content is for educational and informational purposes only and is not personalized financial, legal, or tax advice. Comments and public engagement do not form an advisory relationship and may be moderated for relevance or compliance. Investing involves risk. Full disclosures: https://www.yourwealtharc.com/disclosures