Appealing to lower IRMAA Part B or Part D Medicare premiums

If you are paying high Part B or Part D Medicare premiums, you can appeal to lower them. In most cases, once you enroll in Medicare, you will pay the standard Medicare Part B premium of $144.60 (2020). However, if your income is greater than $87,000 for individual tax filers, or $174,000 for joint filers, you will pay more for Medicare Part B and Part D prescription drug plans. This increase in premiums is due to something called the income-related monthly adjustment amount (IRMAA). The IRMAA adjustment depends on your income, as outlined in the chart below (These can change annually):

If your yearly income in 2018 (for what you pay in 2020) was:What you pay

each month for Part B (2020)

What you pay in addition to your regular Part D premium (2020)
File individual tax returnFile joint tax returnFile married & separate tax return
$87,000 or less$174,000 or less$87,000 or less$144.60$0
above $87,000 up to $109,000$174,001 up to $218,000not applicable$202.40$12.20
$109,001 up to $136,000$218,001 up to $272,000not applicable$289.20$31.50
$136,001 up to $163,000$272,001 up to $326,000not applicable$376.00$50.70
$163,001 and less than $500,000$326,001 up to $750,000$87,001 and less than $413,000$462.70$70.00
$500,000 or above$750,000 and above$413,000 and above$491.60$76.40

 

How IRMAA is determined

The Social Security Administration (SSA) uses IRS data from the previous two years to make IRMAA determinations. As a result, your 2018 taxes will determine your IRMAA for 2020. Suppose you have Medicare Part B and/or Part D and Social Security decides that you will have to pay higher premiums based on your IRMAA determination. In that case, you will receive an Initial IRMAA Determination Notice. The initial determination notice will include information on Social Security's IRMAA determination as well as your appeal rights. Your IRMAA determination applies for one year.  SSA will notify you near the end of the current year if you have to pay an IRMAA for the upcoming year.

Requesting a reevaluation of your initial IRMAA determination

The Office of Medicare Hearings and Appeals (OMHA) handles all appeals to Medicare's IRMAA. When you receive your Initial IRMAA notification, you have the right to appeal if you believe that your IRMAA is incorrect for a qualifying reason such as:

  • You filed an amended tax return for the year SSA is using to make an IRMAA decision
  • There was an error in the IRS data
  • The IRS provided SSA with old data, and you want them to use newer information
  • You had a major life-changing event that significantly reduced your income (See Qualified life-changing events in the section below)

To initiate a reconsideration, you must either call the SSA at 800.772.1213 or write to the SSA.

If you appeal your decision, you will continue to pay an income-related premium amount during the appeal process. If a change to your IRMAA determination occurs, corrections will be retroactive. If you request an appeal, you must:

  • Ask for an appeal within 60 days. The 60 days start the day after you get your letter. SSA assumes that you got the letter five days after the date on it unless you show them you got it after the five-day period.
  • If you wait longer than 60 days, you must have a good reason for waiting to ask for an appeal.
  • You can call 1-800-772-1213 to file your appeal. You can also use Form SSA-561-U2, called “Request for Reconsideration.” You can find this form online at socialsecurity.gov/online/ssa-561.pdf.

Requesting a reevaluation of your IRMAA determination due to life-changing events

Suppose you are paying an IRMAA for Medicare Part B or Part D and experience a life-changing event that could reduce your IRMAA. In that case, you can file for a reevaluation using the Medicare Income-Related Monthly change Amount – Life-Changing Event form. Qualified life-changing events include:

  • Marriage
  • Divorce/Annulment
  • Death of Your Spouse
  • Work Stoppage
  • Work Reduction
  • Loss of Income-Producing Property
  • Loss of Pension Income
  • Employer Settlement Payment

You will be required to provide evidence of your modified adjusted gross income and your life-changing event. You will have to send original documents or certified copies if done by mail (SSA will return them) or show them to the SSA employee if done in person. It is essential to understand that there is no specific timeframe that the SSA must follow concerning your request for redetermination, so it could take a while.

As you consider filing for an IRMA reconsideration either initially or if you have a life-changing event, you should understand that it is not always a black and white process.  My experience has been that even though you may see the appeal as a slam dunk, the SSA does not always see it the same way. Sometimes your IRMAA appeal is granted, but I have seen other times in what seems like similar circumstances they are not. As long as you believe you meet the reconsideration criteria, it doesn’t hurt to file an appeal. If you are paying high Part B or Part D Medicare premiums, you can appeal to lower them, and it won’t cost you anything but time.

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