IRMAA Appeal

womguy

New Member
Turning 65 in December. Since I retired 4 years ago my AGI has been around $425,000 annually due to about $325,000 in annual contractual deferred income payments (the rest due to dividends, interest, capital gains). This suggested I will pay $318.10 in "extra" Part B and $70 in "extra" Part D monthly premiums for the next few years for my wife and me if based upon 2018, 2019 or 2020 1040s. The amount of these contractual deferred income payments will fall to $25,000 so my AGI should be around $125,000 in 2021. Not taking SS until age 70. What is the likelihood of a favorable IRMAA appeal based upon lower future deferred income payments which I could prove? The wild card is div, interest, capital gains.
 

MBSC

Well-Known Member
Medicare looks back two years in determining IRMAA. The 2023 Parts B/D premiums will not include IRMAA if the 2021 tax return shows lower income. The IRMAA Appeal Form below lists specific reasons for when an appeal can be made. Immediate reduction in income due to retirement or death of spouse almost always result in a successful appeal.

You will need to pay IRMAA for December 2020. However, when you receive notice you will be subject to IRMAA in 2021, one reason listed on the form is "Employer Settlement Payment". I am not familiar with the success rate of this option but it can't hurt to submit the appeal for 2021 and see what happens. The worst that can happen is they say no and you pay IRMAA until 2023.

If the 2021 IRMAA appeal is successful, you will still have to pay the IRMAA for a few months but then receive a refund for the overpayments.

IRMAA Appeal Form: https://www.ssa.gov/forms/ssa-44-ext.pdf
 

womguy

New Member
Thanks MBSC for your thorough response. One more question. To the extent that I am unsuccessful on the appeal, I will pay IRMAA in 2021 and 2022. If I then decided to start taking IRA distributions in 2023 would I be entitled to pay no IRMAA in 2023 and 2024 until the higher IRA distribution inflated AGI flows through to my 1040. In other words is there any clawback mechanism in the other direction? Thanks
 

MBSC

Well-Known Member
Thanks MBSC for your thorough response. One more question. To the extent that I am unsuccessful on the appeal, I will pay IRMAA in 2021 and 2022. If I then decided to start taking IRA distributions in 2023 would I be entitled to pay no IRMAA in 2023 and 2024 until the higher IRA distribution inflated AGI flows through to my 1040. In other words is there any clawback mechanism in the other direction? Thanks
There is no clawback. You would have no IRMAA in 2023 and 2024. IRMAA would be applied in 2025 based on the 2023 tax return.
 

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