The Income Related Monthly Adjustment Amount known as IRMAA was implemented by the federal government in 2003 and then expanded in 2013 in an effort to strengthen the financial stability of the Medicare program. Higher income seniors are asked to pay more than the standard Medicare Part B premium and an additional amount for the Medicare Part D prescription drug program. These over-and-above amounts are your IRMAA. If Social Security (SSA) determines that you should pay an IRMAA, they will notify you in writing with their Initial IRMAA Determination. To determine if IRMAA applies, Social Security looks at your Modified Adjusted Gross Income (MAGI) from your federal tax return from two years prior. MAGI is your Adjusted Gross Income with some deductions added back. (For most people, this will be your AGI). Your IRMAA is adjusted annually for the next calendar year; usually looking back at returns from two years prior.
| If you have experienced a life-changing event that caused your income to decrease, or if you think the income information Social Security used to determine your IRMAA was incorrect or outdated, we encourage clients to request an IRMAA redetermination of the initial determination. There is no harm in trying! |
The following are valid life-changing events SSA will consider in redetermining IRMAA:
- Marriage, Death of a spouse, Divorce or annulment
- You or your spouse stopping work or reducing the number of hours you work
- Involuntary loss of income-producing property due to a natural disaster, disease, fraud, or other circumstances
- Loss of pension
- Receipt of settlement payment from a current or former employer due to the employer’s closure or bankruptcy
A proper request for redetermination requires evidence of the event (such as certified marriage certificate, death certificate or divorce decree), and proof of the lower income or an estimate of your lower income. Evidence of lower income could be a copy of an amended tax return with the IRS or a more recent tax return that shows you are receiving a lower income than what is used in Social Security’s determination. If you expect your income will not change until the current year, you can give SSA an estimate of what you think your income will be.
This written proof needs to be submitted with a completed and signed Life-Changing Event form (SA44). You can access this form on this government webpage: https://www.ssa.gov/medicare/lower-irmaa. Follow the instructions for completing and submitting the form.
There is no strict timeline that Social Security must respond by and IRMAA premiums must be paid while a reconsideration is in process.
If your redetermination is successful, your premium amounts will be corrected. If your request is denied, you will be notified in writing. Follow the directions in the denial letter to file an appeal. Go here for more information about appealing denials of your initial request for redetermination: https://www.hhs.gov/about/agencies/omha/the-appeals-process/part-b-premium-appeals/index.html
Best,
Phil Dougherty
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Here are two web pages to learn more about IRMAA:
Q1 Medicare: https://q1medicare.com/PartD-IRMAAReconsiderationAppealsPartD.php
HHS: https://www.hhs.gov/about/agencies/omha/the-appeals-process/part-b-premium-appeals/index.html