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No one likes unnecessary bills or surcharges. Only a few know this, but there is a way to file an Income-Related Monthly Adjustment Amount (IRMAA) appeal. When your income exceeds the threshold, you'll have to pay an extra amount on top of your Medicare Part B and Part D premiums.
If you face IRMAA but suspect an error or have a qualifying situation, you can request reconsideration. It is within your rights to appeal IRMAA. This can allow you to avoid paying IRMAA or get a reduced surcharge.
The IRMAA Appeal Process
Before you make an IRMAA appeal, you need to get acquainted with the IRMAA appeal process.
When Social Security requires you to pay IRMAA, they promptly mail you an initial determination notice. This notice will give you the necessary information to request a new initial determination.
If your income dropped because of a life-changing event, or if Social Security used incorrect income information to calculate your IRMAA, you can request an IRMAA appeal.
Reasons to Appeal IRMAA
There are several reasons why you should consider a Medicare IRMAA appeal. The Social Security Administration (SSA) will typically reconsider IRMAA if you've experienced a life-changing event that lead to your reduced income. Some common IRMAA appeal reasons include:
- Marriage
- Divorce or annulment
- Death of a spouse
- Work stoppage (either you or your spouse)
- Work reduction (either you or your spouse)
- Loss of pension
- Loss of income-producing property due to a natural disaster
- Receipt or reduction of certain forms of assistance like Supplemental Security Income or Medicaid.
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How to Appeal an IRMAA Decision
You should follow these steps to make a successful appeal to IRMAA:
1. Determine If You Are Eligible to Make an IRMAA Appeal
Needing to pay the IRMAA surcharge can be frustrating. However, you need to determine if you have valid grounds for an appeal before acting.
Understanding the eligibility criteria and carefully evaluating your circumstances will enable you to make a strong case and save yourself from unnecessary financial expenses. It's best to seek guidance from a financial planner to help you with this. An informed view of your finances will help you to make the right decisions.
2. Gather Supporting Documentation
You will need supporting evidence to appeal IRMAA. Various forms fall under this category, such as:
- A more recent tax return than the one the SSA used to determine your IRMAA.
- A letter from your employer about your retirement or reduction in work hours.
- Death certificate, in case of a spouse's death.
- Documents related to the loss of a pension or loss of property.
- An amended tax return
3. Fill Out the Required IRMAA Appeal Form
If you're ready to start the appeal process, don't waste any time. You need to appeal IRMAA within 60 days of receiving your notice. You need to fill out Form SSA-44 and get started. The IRMAA Appeal Form lets you explain the life-changing event that lowered your income. You can also provide an estimate of your modified adjusted gross income for the upcoming year.
Form SSA-44 makes it easier to appeal IRMAA. Previously, you needed to write a letter explaining your financial situation. However, having a financial planner work with you can make this part of the process easier if you can.
Your financial planner would have a better understanding of your true MAGI and tax circumstances. A professional can guide you on the best way forward when you appeal IRMAA.
4. Submit the Form and Documentation
Along with Form SSA-44, ensure you include all relevant evidence to your Social Security office to support your claim. Make sure your financial planner knows their role in submitting the form and supporting evidence. Remember, timely submission is essential for a smooth process.
5. Await the Decision
After you submit your request, the SSA will carefully review your application and make a fair decision. If they find your favor, they may adjust your Medicare premium accordingly. There is no set time for how long an IRMAA appeal takes.
What to Do If Your IRMAA Appeal Is Denied
If Social Security denies your reconsideration request and you disagree, you can pursue further appeals. You can request a hearing before an Administrative Law Judge. They will independently review your case, including any new evidence you submit.
If the ALJ fails, you could take it to the DHHS Medicare Appeals Council (MAC). This is a higher-level review where your case is examined again for errors or misjudgments. The last resort is a Federal Court Action. This is the final level of appeal and requires legal assistance.
How Long Does an IRMAA Appeal Take?
The processing time for an IRMAA appeal varies, but most cases take a few weeks to a few months. If approved, Medicare will adjust your premium retroactively, and you may receive a refund for overpaid amounts.
By understanding how to appeal IRMAA, reducing your income strategically, and planning, you can lower your Medicare costs effectively.
How Many Years Does IRMAA Look Back?
Medicare calculates IRMAA based on your tax return from two years ago. For example, 2025 IRMAA charges are based on your 2023 tax return. If your income has significantly decreased since then, filing an IRMAA appeal can help lower your premium.
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Stewart Willis is the founder and president of Asset Preservation Wealth & Tax, a financial planning firm in Phoenix, Arizona. Investment advisory services offered through Foundations Investment Advisors, LLC, an SEC registered investment adviser.
The commentary on this blog reflects the personal opinions, viewpoints and analyses of the author, Stewart Willis, providing such comments, and should not be regarded as a description of advisory services provided by Foundations Investment Advisors, LLC (“Foundations”), an SEC registered investment adviser or performance returns of any Foundations client. The views reflected in the commentary are subject to change at any time without notice. Nothing on this website constitutes investment, legal or tax advice, performance data or any recommendation that any particular security, portfolio of securities, transaction or investment strategy is suitable for any specific person. Personal investment advice can only be rendered after the engagement of Foundations for services, execution of required documentation, including receipt of required disclosures. Any mention of a particular security and related performance data is not a recommendation to buy or sell that security. Foundations manages its clients’ accounts using a variety of investment techniques and strategies, which are not necessarily discussed in the commentary. Any statistical data or information obtained from or prepared by third party sources that Foundations deems reliable but in no way does Foundations guarantee the accuracy or completeness. Investments in securities involve the risk of loss. Any past performance is no guarantee of future results. Advisory services are only offered to clients or prospective clients where Foundations and its advisors are properly licensed or exempted. For more information, please go to https://adviserinfo.sec.gov and search by our firm name or by our CRD # 175083.
