IRMAA Planning: How RMDs Trigger Medicare Surcharges — and How to Avoid Them

For retirees with significant tax-deferred balances, required minimum distributions can push income well above Medicare's surcharge thresholds — adding thousands of dollars per year to what you pay for Parts B and D. The good news: RMD-induced IRMAA is largely preventable with the right sequencing.

What is IRMAA?

IRMAA stands for Income-Related Monthly Adjustment Amount. It's a surcharge the Social Security Administration adds to Medicare Parts B and D premiums when your income exceeds certain thresholds. The adjustment is not gradual — it works as a cliff: one dollar over a tier boundary triggers the full surcharge for that entire tier.

In 2026, the base Medicare Part B premium is $202.90/month. Once your income crosses the first IRMAA threshold, you owe $202.90 plus a surcharge — on top of your existing health coverage costs.¹

2026 IRMAA thresholds and Part B surcharges

IRMAA is determined by your MAGI from two years prior. Your 2026 Medicare surcharge is based on your 2024 tax return. This lookback is what makes RMD planning both critical and complex — the income you generate today affects your Medicare costs two years from now.

Source: CMS, 2026 Medicare Parts B & D Premiums.¹ Part D carries its own surcharge on the same income tiers ($14.50–$91.00/month additional).²

How RMDs push you into IRMAA territory

The connection between RMDs and IRMAA is mechanical. A retiree with $2M in a traditional IRA at age 75 has an RMD of roughly $81,000 that year (balance ÷ 24.6 divisor). Add Social Security ($35K), a small pension ($18K), and modest brokerage income ($8K), and total MAGI reaches ~$142,000 for a single filer — landing squarely in Tier 2 ($974/year surcharge).

As IRA balances compound and RMDs grow, the income stack worsens. By age 83 with a $2.5M IRA, the same retiree's RMD approaches $155,000 — potentially pushing them into Tier 3 without any additional spending or active choices.

Most retirees don't see this coming because:

• The two-year lookback means 2026 IRMAA is based on 2024 income — often the first year of heavy RMDs
• Social Security benefits become increasingly taxable (up to 85%) as income rises, creating a compounding effect
• One-time events — Roth conversions, property sales, inherited IRA distributions — can spike income and trigger IRMAA for a year

Strategy 1: Roth conversions in the pre-RMD window

The most powerful IRMAA mitigation tool is reducing the traditional IRA balance before RMDs begin. Each dollar converted from traditional IRA to Roth in the years before age 73 (or 75) permanently shrinks future RMDs — and therefore future MAGI.

The window: From retirement until RMD age, most retirees are in a relatively low-income period (especially before Social Security starts). This is the time to convert — but you must model the conversion amount against the IRMAA cliff.

Important: Roth conversions raise 2024 MAGI, which drives 2026 IRMAA. Convert carefully to the cliff edge, not across it. A specialist models the two-year lookback explicitly. Use our Roth Conversion Calculator to estimate the tradeoff.

Strategy 2: Qualified Charitable Distributions to offset RMDs

If you're age 70½ or older and give to charity anyway, QCDs are the most efficient IRMAA tool available. A QCD — a direct transfer from your IRA to a qualified 501(c)(3) — counts toward your RMD but is excluded from your MAGI entirely. It doesn't appear as income on your tax return.

In 2026, you can donate up to $111,000 via QCD.³ For a retiree with a $90,000 RMD who gives $25,000 to charity annually: routing that $25,000 as a QCD reduces their RMD income inclusion from $90,000 to $65,000. Depending on their other income, this can keep them under an IRMAA cliff — or reduce it by a full tier.

IRMAA impact by tier example: Married couple at $270,000 MAGI (in Tier 1). A $30,000 QCD reduces MAGI to $240,000 — still Tier 1 but no tier change. However, if they're at $220,000 MAGI, a $5,000 QCD drops them below $218,000 — eliminating IRMAA entirely. The cliff math applies in both directions. Use our QCD Calculator to model your specific situation.

Strategy 3: Income smoothing across the two-year lookback

Because IRMAA uses a 2-year-prior lookback, the income year that matters for 2028 Medicare premiums is 2026. Planning for IRMAA means managing income not just this year, but in the year-before-next as well.

Specific techniques:

• Front-load RMDs in low-income years. You can take more than your RMD in any year (you cannot take less). A retiree expecting a one-time income spike in 2025 (property sale, large capital gain) might take a smaller Roth conversion that year and adjust accordingly.
• Avoid stacking distributions in the same year. Taking an inherited IRA distribution in the same year as a large Roth conversion + RMD creates a compounding spike. Spread across years where possible.
• Plan around Medicare enrollment year. The first year of Medicare typically has a lookback to higher earning years. An IRMAA appeal for this initial-enrollment year (Life Changing Event form SSA-44) can reduce premiums based on current rather than prior income.

Strategy 4: Life Changing Event appeals

IRMAA is based on the most recent available tax return — but SSA allows you to appeal using more current income if a qualifying "Life Changing Event" occurred. LCEs include: retirement, marriage, divorce, death of spouse, reduction in work hours, loss of pension, or employer settlement.

The appeal (SSA Form SSA-44) asks you to estimate current-year MAGI. If you retired mid-year 2024 but your 2023 return shows high working income, the appeal substitutes lower 2024 (or projected) income. Retirees in their first few years of Medicare often have this opportunity and don't use it.

IRMAA and Roth 401(k)/TSP beneficiaries

Starting 2024, Roth 401(k)s and Roth TSP accounts have no lifetime RMDs for the original owner (SECURE 2.0 § 325).⁴ This removed a planning gap that previously forced Roth 401(k) owners to take RMDs anyway. If you have a Roth 401(k), you can now leave it untouched — no RMD, no MAGI inclusion, no IRMAA risk from that account.

Traditional 401(k)s still require RMDs. If you have both traditional and Roth 401(k) balances, this distinction matters for IRMAA planning — keep Roth 401(k) funds untouched and take traditional 401(k) RMDs as required.

What a specialist does that generic planning misses

IRMAA-aware retirement planning requires modeling at least three years simultaneously: this year's distribution decisions, next year's tax return, and the Medicare premiums those generate two years out. A generalist CFP managing accumulation clients rarely has this workflow built in.

An advisor who specializes in retirement distribution strategy will:

• Model your RMD glidepath against IRMAA thresholds through age 90
• Identify which years to convert aggressively vs. hold back
• Integrate QCD amounts into the income plan, not as an afterthought
• Flag the cliff-year risk (the year an RMD first crosses a tier boundary)
• Coordinate Roth conversion amounts with Social Security timing and pension income

Sources

1. CMS — 2026 Medicare Parts B Premiums and Deductibles. Base Part B premium $202.90/month; IRMAA surcharges $81.20–$487.00/month. Published November 2025.
2. Kiplinger — Medicare Premiums 2026: IRMAA Brackets and Surcharges for Parts B and D. Full tier schedule for Parts B and D; income thresholds $109,000–$500,000 single filer.
3. IRS — Qualified Charitable Distributions. 2026 annual QCD limit: $111,000 (inflation-indexed per SECURE 2.0). Available from age 70½.
4. IRS — Retirement Topics: RMDs. SECURE 2.0 § 325: Roth 401(k) and Roth TSP accounts no longer subject to lifetime RMDs, effective 2024.

IRMAA thresholds and Medicare premiums verified against CMS 2026 published rates and Kiplinger analysis, April 2026. Medicare premiums are adjusted annually; confirm current-year values at medicare.gov before planning.