SSA-44 and IRMAA Appeals: What to Know Before You File

How is IRMAA calculated? The income lookback

IRMAA means income-related monthly adjustment amount. It can apply to Part B and Part D when income exceeds the threshold for your filing status and coverage year. Medicare IRMAA uses MAGI: adjusted gross income plus tax-exempt interest. SSA generally uses a return from 2 years earlier; if that return is unavailable, it may use the return from 3 years earlier. (SSA: Medicare premiums for higher-income beneficiaries)

For example, under the usual 2-year lookback, 2025 income generally informs 2027 IRMAA. A retirement-year income drop might not appear in the return SSA used. Compare your letter with your records before choosing a request route. (SSA: Medicare premiums for higher-income beneficiaries)

Annual figures update each fall. We do not state 2027 IRMAA or Part B dollar amounts here. Use our IRMAA brackets and calculator page for annual context, and confirm the released figures for the relevant year with SSA and CMS.

Which life-changing events are listed on SSA-44?

SSA recognizes these 8 event categories. The event must cause an income reduction that decreases or eliminates IRMAA; lower income alone is not always enough. (SSA: Form SSA-44 and instructions (PDF)) (SSA POMS HI 01120.005: life-changing events)

• Marriage. Report the event and the resulting income and filing-status change.
• Divorce or annulment. Report the event and newer income and filing status.
• Death of a spouse. SSA reviews the event and income change.
• Work stoppage. This may include the beneficiary or spouse retiring or otherwise stopping work.
• Work reduction. Reduced work hours for the beneficiary or spouse may qualify.
• Loss of income-producing property. The loss must be beyond your control, such as a disaster or theft. Voluntarily selling property does not meet this category.
• Loss of pension income. Certain defined-benefit or cash-balance pension changes, including plan failure, termination or scheduled cessation, may qualify.
• Employer settlement payment. A settlement tied to an employer’s closure, bankruptcy or reorganization, followed by lower income, may qualify.

For the limits on property, pension and settlement events: (SSA POMS HI 01120.035: income-producing property loss) (SSA POMS HI 01120.040: pension income loss) (SSA POMS HI 01120.043: employer settlement)

What documents should you prepare?

Use the current SSA-44 form and read its instructions. We suggest organizing the following before submitting anything to SSA. Keep financial documents with SSA and your tax professional, not in an agency inquiry email. (SSA: Form SSA-44 and instructions (PDF)) (SSA: Medicare premiums for higher-income beneficiaries)

On a phone, scroll the table sideways to read both columns.

Evidence references: (SSA: Form SSA-44 and instructions (PDF)) (SSA POMS HI 01120.025: work reduction) (SSA POMS HI 01120.035: income-producing property loss) (SSA POMS HI 01120.040: pension income loss) (SSA POMS HI 01120.043: employer settlement)

An estimate should reflect the full relevant tax year, not only the months after retirement. Your tax professional can help account for wages, distributions, taxable gains and other income. SSA asks people using estimates to provide a signed return once it is filed; estimates can also be updated. (SSA: Form SSA-44 and instructions (PDF)) (SSA POMS HI 01120.065: revised income estimates)

How to complete and submit SSA-44

1. Review the letter. Identify the premium year and income information used. If the issue is incorrect or amended tax data rather than an event, ask SSA about correcting the record.
2. Identify the event and date. Use the form’s categories; describe the qualifying event, not just that income is lower.
3. Enter newer-year income and filing status. Follow the instructions for any current-year estimate and additional year requested. Have your tax professional verify MAGI.
4. Sign and provide evidence. Follow the current form and document instructions. Keep copies of what you submit.
5. Submit directly to SSA. Its request-to-lower-IRMAA page offers an online SSA-44 route. SSA also says you can fax or mail the completed form and evidence to a Social Security office. Use SSA’s site to find the destination; do not send the form to us.

Submission references: (SSA: request to lower IRMAA) (SSA: Form SSA-44 and instructions (PDF))

For help identifying the SSA process, call Social Security at 1-800-772-1213 (TTY 1-800-325-0778). (SSA: request to lower IRMAA)

What happens after you submit?

SSA reviews the event and income information and makes the determination. It may ask for more evidence or a filed return supporting an estimate. Read the decision for the income year and effective period accepted. A submitted form does not itself establish a new amount owed. (SSA POMS HI 01120.005: life-changing events) (SSA POMS HI 01120.065: revised income estimates)

If SSA approves a new determination, the effective period depends on when the event occurred, when it affected income, when you requested review and when the relevant Medicare coverage began. We do not promise a refund or processing time. Ask SSA how the decision affects your billing. (SSA POMS HI 01120.005: life-changing events)

If both spouses have adjustments affected by the event, each should contact SSA. A report by one spouse does not automatically update the other spouse’s IRMAA. (SSA POMS HI 01120.005: life-changing events)

SSA-44 versus a formal IRMAA appeal

Life-changing event: an SSA-44 request asks for a new initial determination using newer income. Disagreement with a decision: reconsideration is a formal appeal route, generally requested within 60 days after receiving the determination notice. SSA can consider good cause for a late request. Follow your notice for the applicable process. (SSA: Medicare premiums for higher-income beneficiaries) (SSA POMS HI 01140.001: IRMAA appeal process)

SSA describes an online appeal option and a written Request for Reconsideration, Form SSA-561-U2. An amended return or proof that the income data is wrong may instead support a correction or new determination. Ask SSA which route fits; the 60-day appeal rule is not a universal SSA-44 deadline. (SSA: Medicare premiums for higher-income beneficiaries) (SSA POMS HI 01140.001: IRMAA appeal process)

How to avoid IRMAA: what planning can and cannot do

There is no universal way to avoid IRMAA. Income, filing status and the coverage-year thresholds determine whether it applies. Your tax professional can model how taxable income decisions may affect a later Medicare year. Medicare IRMAA counts tax-exempt interest as well as adjusted gross income. (SSA: Medicare premiums for higher-income beneficiaries)

Do not assume SSA-44 can undo an adjustment caused only by a Roth conversion or capital gain. Tax planning and an SSA life-changing-event review are different tasks. (SSA POMS HI 01120.005: life-changing events)

Our Medicare Guide for CPAs and Financial Advisors connects this topic with HSA contribution timing and enrollment questions.

Questions we hear

What is Form SSA-44?

SSA-44 is Social Security’s Medicare Income-Related Monthly Adjustment Amount – Life-Changing Event form. It can request a new IRMAA determination after a qualifying event reduces income enough to decrease or eliminate the adjustment. It is different from a formal appeal.

How is IRMAA calculated?

Social Security uses modified adjusted gross income, meaning adjusted gross income plus tax-exempt interest, and the threshold for your filing status and Medicare year. The usual income lookback is 2 years; SSA may use an earlier return if the usual one is unavailable.

When does IRMAA kick in?

IRMAA applies to the Part B or Part D coverage you have when SSA determines income exceeds the applicable threshold. It is not a late enrollment penalty. Your decision notice explains the amount and the income year used.

Can we avoid IRMAA by filing SSA-44 after a Roth conversion?

A Roth conversion alone is not a qualifying life-changing event. A separate event such as work stoppage may support a new determination if it meets SSA’s rules and reduces income enough. A tax professional can model income; SSA makes the decision.

Is there a 60-day deadline for SSA-44?

The general 60-day deadline applies to requesting reconsideration after receiving an IRMAA determination notice. A life-changing-event request for a new determination has different timing and effective-year rules. Follow your notice and ask SSA which process applies.

Can both spouses use one SSA-44 request?

Each spouse whose IRMAA may be affected should contact SSA. A report by one spouse does not automatically change the other spouse’s determination.

Sources and rule references

References checked November 6, 2026 (MT). Use the current agency instructions for a personal decision.

1. SSA: Medicare premiums for higher-income beneficiaries
2. SSA: request to lower IRMAA
3. SSA: Form SSA-44 and instructions (PDF)
4. SSA POMS HI 01120.005: life-changing events
5. SSA POMS HI 01120.025: work reduction
6. SSA POMS HI 01120.035: income-producing property loss
7. SSA POMS HI 01120.040: pension income loss
8. SSA POMS HI 01120.043: employer settlement
9. SSA POMS HI 01120.065: revised income estimates
10. SSA POMS HI 01140.001: IRMAA appeal process
11. Medicare.gov: contact Medicare