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.
 

topcatone

New 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
I'm in a similar situation. I retired Oct 1, 2020. For 2020 made enough to trigger IRMAA on top of Med B. I submitted the appeal form after I got a huge Med B bill (after I joined Medicare in July). I submitted a letter to SS from my employer saying I had retired. I can't find a specific answer on the web, and SS didn't answer the question either on my first call with them. Result was a confusing letter that didn't change anything. Starting now, and in 2021, I will have almost zero income and depend upon my spouse. Does my IRMAA go to $0 Jan 2021, or will it go to zero in Jan 2023 after my 2021 tax return shows no income? Crazy to pay that much a month now!
 

MBSC

Well-Known Member
I'm in a similar situation. I retired Oct 1, 2020. For 2020 made enough to trigger IRMAA on top of Med B. I submitted the appeal form after I got a huge Med B bill (after I joined Medicare in July). I submitted a letter to SS from my employer saying I had retired. I can't find a specific answer on the web, and SS didn't answer the question either on my first call with them. Result was a confusing letter that didn't change anything. Starting now, and in 2021, I will have almost zero income and depend upon my spouse. Does my IRMAA go to $0 Jan 2021, or will it go to zero in Jan 2023 after my 2021 tax return shows no income? Crazy to pay that much a month now!
If I understand your post correctly, you paid IRMAA for the second half of 2020 because you submitted the appeal form but nothing changed. If you have not recently received a 2021 IRMAA notice, then your appeal request is being applied to 2021 Part B premiums and you should pay the standard Part B premium of $148.50. You do not need to take additional action at this time.

If you have recently received a new IRMAA notice stating it will be applied to 2021 Part B premiums, then you need to submit another appeal request if 2021 household income will be below the $176,000 threshold.

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

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