How to Appeal Your IRMAA Medicare Surcharge

Your 2026 Medicare premium surcharge is based on your 2024 income. If your income dropped since then — due to retirement, a spouse's death, or another significant event — you may be paying a surcharge based on income you no longer have. The Social Security Administration has a formal process to correct this using Form SSA-44.

The Two-Year Lookback Problem

IRMAA (Income-Related Monthly Adjustment Amount) is calculated using a two-year lookback: your 2026 Medicare surcharge is based on your 2024 tax return.¹ For retirees who had a large RMD, Roth conversion, or business-sale in 2024, that one-time income spike creates two years of elevated Medicare premiums — even though your 2025 and 2026 income is much lower.

The 2026 surcharges per person range from $1,148/yr (Tier 1) to $6,936/yr (Tier 5). For a married couple both on Medicare, those amounts double. A $2-over-the-threshold scenario can cost a couple nearly $14,000 extra per year.¹

Three paths to reduce IRMAA:

File Form SSA-44 — if a life-changing event lowered your income, SSA will use a more recent year to set your surcharge
Correct a tax return error — if SSA used incorrect income data, file an amended return and notify SSA
Proactively reduce future income — QCDs, income smoothing, and Roth conversion sequencing (see IRMAA Planning Guide)

Form SSA-44: Who Qualifies

Form SSA-44 (Medicare Income-Related Monthly Adjustment Amount — Life-Changing Event) lets you ask SSA to substitute a more recent year's income in place of the standard two-year lookback. You must have experienced one of eight qualifying life-changing events (LCEs) that reduced your income.²

The 8 qualifying life-changing events

Event	Common example for retirees	Key evidence required
Marriage	Newly married; combined income now lower than individually	Marriage certificate
Divorce or legal separation	Split reduced income-producing assets	Divorce decree
Death of a spouse	Surviving spouse loses pension or SS benefit from deceased	Death certificate
Work stoppage	Retired from full-time employment mid-year	Letter from employer confirming retirement date
Work reduction	Shifted from full-time to part-time employment	Statement of reduced hours and compensation
Loss of income-producing property	Rental property sold or destroyed, eliminating rental income	Documentation of property loss or sale
Loss of pension income	Pension terminated due to employer plan failure or restructuring	Letter from plan administrator
Employer settlement payment	Prior-year income included a one-time settlement that won't recur	Settlement documentation

Important: A one-time RMD or Roth conversion spike is not by itself a qualifying LCE — those are investment decisions, not life events. However, retirement (work stoppage) is one of the most common qualifying events for retirees who had employment income in the lookback year.

Step-by-Step: Filing SSA-44

Step 1 — Get the form

Download Form SSA-44 (current edition: December 2025) from ssa.gov/forms/ssa-44.pdf. Use only the current version — SSA rejects outdated editions.³

Step 2 — Identify your LCE and income estimate

Select the qualifying event that applies. Then estimate your income for the year you want SSA to use. You can request SSA use either:

Your most recently filed tax return year (if your income dropped more recently than the lookback year)
Your current-year estimated income (if the LCE just occurred and you don't yet have a return)

You'll need to certify the estimate and show the LCE occurred before January 1 of the year the IRMAA is being assessed.

Step 3 — Gather documentation

Copy of the relevant tax return(s)
Proof of the LCE (employer retirement letter, death certificate, divorce decree, settlement documents)
A written income estimate if using a year for which no return exists

Step 4 — Submit

You have three options:²

Mail or fax Form SSA-44 + documents to your local Social Security office
In person at a local SSA office (no appointment required but recommended)
By phone — call 800-772-1213 and tell the representative you want to lower your IRMAA due to a qualifying event

Step 5 — Deadline

File within 60 days of receiving the IRMAA notice. You can still file after 60 days, but SSA is not required to retroactively adjust. Early filing maximizes the refund window.

What Happens During the Appeal

You continue paying the surcharge while SSA reviews your request. If approved, SSA adjusts your premium going forward and issues a retroactive refund for any overpaid amounts.

Official timeline: 30–45 days. Real-world timeline: 60–120 days for a decision, then an additional 60–150 days for the refund to process.⁴ Plan accordingly — don't count on the refund arriving within 90 days.

What to do while waiting: Keep paying the surcharge. Stopping payment can result in Part B coverage suspension. Track the submission date and follow up with SSA at the 45-day mark if you've heard nothing.

If Your Appeal Is Denied: Four Levels

SSA denials are not final. You have four appeal levels, each escalating to a higher authority:²

Reconsideration — a different SSA employee reviews the file. File within 60 days of denial.
Office of Medicare Hearings and Appeals (OMHA) — an administrative law judge hears your case. File within 60 days of reconsideration denial.
Medicare Appeals Council — reviews OMHA decisions. File within 60 days of OMHA ruling.
Federal district court — final appeal for significant surcharge amounts. File within 60 days of Appeals Council decision.

For Tiers 4–5 ($6,356–$6,936/yr per person), the math clearly justifies pursuing all available levels if the underlying facts support the appeal.

If You Don't Have a Qualifying LCE

Many retirees hit with a large IRMAA from a one-time RMD or Roth conversion don't have a qualifying life-changing event — the income spike was planned or at least voluntary. In that case, the SSA-44 route is unavailable. Your options are:

Wait two years. If the spike was a one-time event, your 2028 IRMAA will be based on your lower 2026 income.
Use QCDs to reduce future income. Qualified Charitable Distributions up to $111,000/yr (2026) excluded from MAGI entirely — not just deducted from AGI. A $20,000 QCD can drop a couple from IRMAA Tier 2 to Tier 1, saving $3,474/yr in premiums. See the QCD Calculator.
Roth conversion sequencing. Pre-RMD Roth conversions reduce the future forced-distribution base. Each $100K converted before age 73 eliminates roughly $4K–$6K in annual RMDs at age 80 — and the IRMAA exposure that comes with them. See the IRMAA Calculator to model your current exposure.

The IRMAA Two-Year Planning Window

Every action you take today affects your Medicare costs in two years. The IRMAA two-year lookback means:

A large Roth conversion in 2026 creates IRMAA risk in 2028
QCDs taken in 2026 reduce your 2028 IRMAA exposure
A large RMD or capital-gain event in 2026 that you cannot avoid still has a two-year window before it hits Medicare premiums — enough time to plan a response

Retirees managing large tax-deferred accounts often benefit from working with an advisor who models the IRMAA trajectory year by year alongside RMD obligations, Roth conversion windows, and QCD capacity — rather than optimizing one variable at a time.

Get expert IRMAA and RMD planning

Modeling the IRMAA two-year lookback alongside RMDs, Roth conversions, and QCDs requires knowing the whole picture. A specialist advisor can build a year-by-year retirement income plan that minimizes Medicare surcharges across your full distribution horizon. Free match, no obligation.

Values verified June 2026 against CMS 2026 fact sheet and SSA.gov. IRMAA brackets and surcharge amounts are set annually; verify current-year thresholds at ssa.gov if reading after 2026.