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If you are a Medicare beneficiary in Georgia and you got a letter from Social Security telling you that your Medicare Part B premium for 2026 will be more than the standard $202.90 per month, you are looking at IRMAA. The Income-Related Monthly Adjustment Amount is the federal surcharge that high-income Medicare beneficiaries pay on top of the standard Part B and Part D premium. It is not a penalty, it is not a fee, it is not optional. It is a separate premium component established by Section 1839(i) of the Social Security Act for Part B (added by the Medicare Prescription Drug, Improvement, and Modernization Act of 2003, Public Law 108-173, Section 811, signed by President George W. Bush on December 8, 2003, effective January 1, 2007) and by Section 1860D-13(a)(7) of the Social Security Act for Part D (added by the Patient Protection and Affordable Care Act, Public Law 111-148, Section 3308, signed by President Obama on March 23, 2010, effective January 1, 2011).

This guide is for Georgia residents and their families. We walk through the statute, the 2026 dollar amounts at every income bracket for every tax filing status, the two-year tax return look-back methodology, the Modified Adjusted Gross Income definition that drives everything, the eight categories of life-changing events that let you ask for a reconsideration on Form SSA-44, the tax planning strategies that can help you stay below the next IRMAA cliff, and what to do when Social Security says no. We also cover the hold-harmless limitation, how IRMAA interacts with Medicare Savings Programs and Extra Help, and how the IRMAA framework treats Married Filing Separately taxpayers differently than every other filing status. About 130,000 to 150,000 Georgia Medicare beneficiaries pay IRMAA every year, concentrated in metro Atlanta and along the I-75 corridor. If you are one of them, you are not alone, and you have more options than the letter from Social Security suggests. :::

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Key takeaways for Georgia high-income Medicare beneficiaries

  1. IRMAA is a surcharge, not a penalty. It is the income-tested portion of your Part B and Part D premium, established by Section 1839(i) (Part B, MMA 2003) and Section 1860D-13(a)(7) (Part D, ACA Section 3308). About 7 to 8 percent of Medicare beneficiaries nationally pay it, which translates to roughly 130,000 to 150,000 Georgians.

  2. 2026 IRMAA is based on your 2024 federal tax return. Social Security uses a two-year look-back. The Modified Adjusted Gross Income (MAGI) figure that determines your 2026 surcharge is your 2024 Adjusted Gross Income (Form 1040 Line 11) plus tax-exempt interest plus excluded foreign earned income. It is not the same as taxable income.

  3. There are five income brackets above the standard premium. For 2026, single filers with MAGI above $109,000 hit the first IRMAA tier. The top tier kicks in at $500,000 single or $750,000 married filing jointly. Each bracket is a cliff: one dollar over the threshold and your full-year premium jumps to the next tier.

  4. Tax filing status matters enormously. Married filing jointly thresholds are double single thresholds ($218,000 entry for MFJ). Head of household uses single thresholds. Married filing separately is the harshest: a threshold of approximately $109,000, and above that you jump straight to the highest tier.

  5. Form SSA-44 lets you ask for a reconsideration after a life-changing event. The eight qualifying events are death of spouse, marriage, divorce or annulment, work stoppage, work reduction, loss of income-producing property, loss of pension income, and employer settlement payment. Selling stock, taking a Roth conversion, and getting a year-end bonus are not life-changing events under Social Security's definition.

  6. Part B IRMAA is withheld from your Social Security check. Part D IRMAA is direct-billed by Medicare regardless of whether your Part D plan is standalone or bundled inside Medicare Advantage. If you do not pay the Part D IRMAA bill, your Part D coverage can be terminated.

  7. You can appeal. The reconsideration is handled by Social Security under 20 CFR 418 Subpart B. If denied, you can request an Administrative Law Judge hearing, then the Appeals Council, then federal district court. Brevy and the GeorgiaCares SHIP at 1-866-552-4464 can help.

  8. Tax planning is your best long-term defense. Roth conversions in low-income years before age 63, capital gain harvesting, Qualified Charitable Distributions up to the annual IRS limit, and bunching deductions can keep MAGI below the next bracket. The cliff structure means a single planning move can save thousands. :::

What IRMAA actually is, and why Congress created it

Medicare Part B has a standard monthly premium that almost everyone pays. For 2026 the standard premium is $202.90 per month, established under Section 1839(a) of the Social Security Act. Historically, this premium was designed to cover approximately 25 percent of the projected per-capita cost of Part B services for aged beneficiaries, with the remaining 75 percent paid by the Supplementary Medical Insurance trust fund from general tax revenues. The federal government, in other words, subsidizes three-quarters of every retiree's Part B coverage.

Beginning in the late 1990s and early 2000s, Congress noticed something. The general subsidy was the same regardless of whether the beneficiary was a retired schoolteacher living on a $24,000 Social Security check or a retired surgeon with $400,000 in annual investment income. Both paid the same Part B premium. Both received the same 75 percent federal subsidy. That equity question, combined with growing fiscal pressure on the Medicare trust funds, led to a major shift in 2003.

The Medicare Prescription Drug, Improvement, and Modernization Act of 2003 was signed by President George W. Bush on December 8, 2003. The headline provision of the law was Part D, the new outpatient prescription drug benefit that took effect January 1, 2006. Tucked into Section 811 of the same statute, however, was a separate provision that amended Section 1839 of the Social Security Act by adding a new subsection (i). That subsection created the first IRMAA: a Part B premium surcharge that took effect January 1, 2007 and that increased the premium paid by Medicare beneficiaries whose income exceeded specified thresholds. The MMA structure was deliberate. The federal subsidy would shrink as income rose, with high-income beneficiaries eventually paying as much as 80 percent of their per-capita Part B cost themselves while the standard 25-to-75 split remained for everyone else.

The IRMAA framework expanded in 2010. The Patient Protection and Affordable Care Act, signed by President Obama on March 23, 2010, included Section 3308, which amended Section 1860D-13 of the Social Security Act by adding a new paragraph (a)(7). The new paragraph created a parallel IRMAA structure for Part D, the prescription drug benefit. Part D IRMAA took effect January 1, 2011 and uses the same income thresholds, the same tax-return look-back, and the same Modified Adjusted Gross Income definition as Part B IRMAA. The ACA also froze the Part B IRMAA brackets in nominal dollars for an extended period and made other adjustments designed to increase the number of beneficiaries paying IRMAA over time.

The Bipartisan Budget Act of 2018, signed by President Trump on February 9, 2018, made the most recent significant structural change. Section 53114 of that statute, Public Law 115-123, added a new fifth IRMAA tier at the very top of the income distribution, effective January 1, 2019. Before 2018 there were four tiers above the standard premium. After 2018 there are five. The top tier today applies to single filers with MAGI of $500,000 or more and married couples filing jointly with $750,000 or more. The Inflation Reduction Act of 2022, Public Law 117-169, did not change the IRMAA brackets directly but reduced overall Part D out-of-pocket exposure in ways that interact with IRMAA, especially the $2,000 out-of-pocket cap on covered Part D drugs that took effect January 1, 2025.

The result is a system that today applies to about 7 to 8 percent of Medicare beneficiaries nationally, raises substantial revenue for the trust funds, and has become a major focus of retirement and tax planning in upper-middle-class and high-income households. For Georgia, where Medicare enrollment is concentrated in metro Atlanta (especially Fulton, Cobb, DeKalb, Gwinnett, Forsyth, and North Fulton areas, where median household incomes and retirement asset balances run well above the state average), IRMAA affects an estimated 130,000 to 150,000 beneficiaries every year.

The two-year look-back: why 2026 IRMAA uses your 2024 tax return

Every IRMAA conversation has to start with the look-back. The Social Security Administration determines your IRMAA for the current calendar year using your federal income tax return from two calendar years earlier. The reason is administrative. SSA needs an IRS-verified income figure to calculate the surcharge, and the most recently filed return available to SSA at the time it sets premiums for the upcoming year is the return from two years prior. The mechanics are described in 20 CFR 418 Subpart B and in the SSA Program Operations Manual System (POMS) HI 01101.

In practice the look-back works like this. In late 2025, the Centers for Medicare and Medicaid Services publishes the Part B premium amounts for calendar year 2026, including IRMAA tier amounts. The Social Security Administration then receives income data from the IRS based on tax returns filed for tax year 2024. SSA uses your 2024 MAGI to determine your IRMAA bracket for 2026. You typically receive an initial determination notice from SSA in late November or December 2025. That notice tells you what your 2026 IRMAA will be, what bracket you fell into, and what your tax return showed.

If you filed your 2024 return on extension and SSA does not have a 2024 return when it sets your premium, SSA will fall back to your 2023 return. If neither is available, SSA may use information from the Social Security earnings record or default to the standard premium. Once the IRS later transmits the 2024 return, SSA will re-determine your IRMAA and either bill or refund the difference.

The look-back creates a structural quirk that catches a lot of Georgia retirees. Your IRMAA is based on income that may have been earned during your final working years, not during your retirement. A surgeon who earned $400,000 in 2024, retired at the end of 2024 at age 64, started Medicare at 65 in mid-2025, and is now living on Social Security plus modest withdrawals of $80,000 per year will still pay the top-tier IRMAA in 2026 because SSA looks at the 2024 return. That is exactly the situation the SSA-44 form was created to address through the work stoppage life-changing event, which we walk through in detail below.

Modified Adjusted Gross Income: the figure that drives every IRMAA decision

The IRMAA brackets are denominated in Modified Adjusted Gross Income. MAGI is not Adjusted Gross Income. MAGI is not taxable income. MAGI is not gross income. MAGI for IRMAA purposes is a very specific number defined under Section 1839(i)(4) of the Social Security Act.

MAGI equals:

  1. Adjusted Gross Income from Form 1040 Line 11, plus
  2. Tax-exempt interest from Form 1040 Line 2a, plus
  3. Excluded foreign earned income under IRC Section 911.

That is the entire definition. It is narrower than the MAGI definitions used elsewhere in the tax code (for example, the MAGI used for Affordable Care Act premium tax credits adds Social Security benefits and untaxed interest differently). For IRMAA, Social Security benefits are included only to the extent they are already taxable and reflected in your AGI. Roth IRA distributions are not included because qualified Roth distributions are not in AGI. Roth IRA conversions, however, are included because the converted amount flows through AGI in the year of conversion.

The implications for Georgia retirees are significant.

Municipal bond interest counts. A retiree holding $2 million in Georgia municipal bonds yielding 4 percent receives $80,000 of tax-exempt interest. That $80,000 is added back into MAGI for IRMAA purposes even though it is excluded from federal taxable income. A retiree with $50,000 of AGI plus $80,000 of muni interest has IRMAA MAGI of $130,000, which puts a single filer into the second IRMAA tier.

Roth conversions count in the year of conversion. A retiree who converts $200,000 from a traditional IRA to a Roth IRA in 2024 will have that $200,000 included in 2024 AGI and therefore in 2024 MAGI. That MAGI drives 2026 IRMAA. Roth conversions performed in a single concentrated year often push retirees into the top one or two IRMAA tiers for the corresponding two-year-later premium year, which is why conversion planning is so closely tied to IRMAA planning.

Capital gains count. A retiree selling a long-held family business or a portfolio of low-basis stock will have the gain flow through AGI. A $500,000 long-term capital gain in 2024 will likely push the seller into the top IRMAA tier for 2026 regardless of how modest their ordinary income looks.

Required Minimum Distributions count. Once a traditional IRA owner reaches age 73 (the current RMD start age after the SECURE Act 2.0 changes), required distributions flow through AGI. A retiree with $2 million in a traditional IRA who is age 75 has an RMD divisor of approximately 24.6, producing an annual RMD of approximately $81,300 added to other income. RMDs are a leading IRMAA driver in metro Atlanta because they are not optional and they cannot be timed.

Qualified Charitable Distributions reduce MAGI. A QCD from a traditional IRA directly to a qualifying charity is excluded from gross income up to the annual IRS limit per individual. QCDs satisfy RMD requirements while keeping the RMD amount out of AGI and therefore out of MAGI for IRMAA. For charitably inclined Georgia retirees with large traditional IRA balances, the QCD is one of the most powerful IRMAA tools available.

Capital losses can offset gains. Capital losses offset capital gains dollar-for-dollar and can offset up to $3,000 of ordinary income per year, with the remainder carried forward. Tax-loss harvesting in years when you are close to an IRMAA cliff can keep MAGI below the threshold.

The 2026 IRMAA brackets, every tier and every dollar amount

For calendar year 2026, the standard Part B premium is $185.00 per month. The standard Part D base beneficiary premium for 2026 is approximately $36.78. The five IRMAA brackets above standard apply on top of those baseline figures. Brackets are denominated in 2024 MAGI because of the two-year look-back.

Single filers, head of household, and married filing jointly when only one spouse files Medicare

MAGI range (2024) Part B premium (2026) Part D IRMAA (2026) Combined monthly add-on
$103,000 or less $185.00 (standard) $0 $0
$103,001 to $129,000 $259.00 $13.70 $87.70
$129,001 to $161,000 $369.40 $35.30 $219.40
$161,001 to $193,000 $480.20 $57.00 $352.20
$193,001 to $499,999 $590.60 $78.60 $484.60
$500,000 or more $628.90 $85.80 $529.70

Married filing jointly

MAGI range (2024) Part B premium (2026) Part D IRMAA (2026) Combined monthly add-on per spouse
$206,000 or less $185.00 (standard) $0 $0
$206,001 to $258,000 $259.00 $13.70 $87.70
$258,001 to $322,000 $369.40 $35.30 $219.40
$322,001 to $386,000 $480.20 $57.00 $352.20
$386,001 to $749,999 $590.60 $78.60 $484.60
$750,000 or more $628.90 $85.80 $529.70

Married filing separately

This is the harshest filing status. The MFS thresholds are compressed and the surcharge jumps quickly to the top tier. The MFS structure was set by statute and has never been updated.

MAGI range (2024) Part B premium (2026) Part D IRMAA (2026) Combined monthly add-on
$106,000 or less $185.00 (standard) $0 $0
$106,001 to $394,000 $590.60 $78.60 $484.60
$394,001 or more $628.90 $85.80 $529.70

A married couple filing separately where each spouse has MAGI of $110,000 (each just $4,000 above the $106,000 threshold) will both pay tier 4 IRMAA. The annual impact for the couple is approximately $11,630 in additional premiums, even though their combined MAGI of $220,000 would put them in tier 1 if they had filed jointly. The MFS structure is so punitive that Brevy generally recommends Georgia married couples avoid MFS filing during Medicare years unless there is a compelling non-IRMAA reason (commonly: income-driven student loan repayment for one spouse, a pending divorce, or liability protection from a spouse's tax issues).

The cliff effect

IRMAA brackets are cliffs, not phase-ins. One dollar over the threshold and the full-year surcharge jumps to the next tier. A single filer with MAGI of $103,000 pays no IRMAA. A single filer with MAGI of $103,001 pays $74.00 per month more for Part B plus $13.70 per month more for Part D, or $1,052 per year, in exchange for that one extra dollar of income. The cliff structure is why year-end income management matters so much for households near a bracket boundary. We discuss specific strategies later in this guide.

Annual recalculation: the surcharge resets every year

IRMAA is not a permanent label. SSA recalculates every year using the most recent available tax return. A retiree who paid top-tier IRMAA in 2026 because of 2024 income may pay no IRMAA in 2027 if 2025 income drops below the threshold. The annual recalculation is automatic. You do not need to file Form SSA-44 just because your income has gone back down. The 2025 return you file in early 2026 will become the basis for 2027 IRMAA, and SSA will adjust your premium accordingly when it sets 2027 amounts in late 2026.

The practical implication is that IRMAA is a year-by-year exposure. A one-time income event (selling a business, a large Roth conversion, a final-year W-2 bonus) creates one bad IRMAA year two years later, not a lifetime of high premiums. That is fundamentally different from how many retirees mentally model the surcharge. It also means tax planning around IRMAA is a multi-year game. Spreading a large Roth conversion over four years rather than executing it in a single year may keep the retiree in a lower IRMAA bracket each year and save tens of thousands of dollars in cumulative premiums.

Form SSA-44 and the eight life-changing events

Section 1839(i)(4)(C) of the Social Security Act authorizes SSA to use a more recent tax return or projected income when the beneficiary has experienced a "major life-changing event." The implementing regulation at 20 CFR 418.1201 and following sections defines the qualifying events and the reconsideration process. The form used is SSA-44, "Medicare Income-Related Monthly Adjustment Amount: Life-Changing Event."

The eight qualifying life-changing events are:

1. Death of spouse

You can use SSA-44 to ask SSA to recalculate IRMAA based on a more recent tax return or projected income when your spouse has died. This is especially important for surviving spouses who file jointly with their deceased spouse for the year of death but will file as a single person (or qualifying widow(er)) in future years, which moves them to the lower single-filer thresholds.

2. Marriage

Marriage changes filing status from single to married filing jointly (or married filing separately). The MFJ thresholds are double the single thresholds, so marriage may either lower or raise the IRMAA depending on the spouses' combined income.

3. Divorce or annulment

Divorce changes filing status from MFJ to single or head of household. A retiree whose joint income was $300,000 (well into IRMAA tier 2 for MFJ) may have post-divorce single income of $120,000 (tier 1 for single). The SSA-44 can capture this immediately.

4. Work stoppage

This is the most commonly used SSA-44 event. If you have stopped working (typically retirement), you can ask SSA to use a projected MAGI based on your post-retirement income rather than your last working-year tax return. The reconsideration can substantially lower or eliminate IRMAA for retirees in their first year or two on Medicare. Documentation typically includes a letter from the former employer confirming the retirement date, evidence of pension or Social Security commencement, and an estimate of projected income for the current and following year.

5. Work reduction

A partial work reduction (for example, going from full-time to part-time, or from $300,000 of annual income to $80,000) can also qualify. The reduction must be significant and documented.

6. Loss of income-producing property

If you lose property that was producing income through a disaster, theft, casualty, or other involuntary loss (and not a sale), and the loss reduces your income going forward, you can request a reconsideration. A common example: a Georgia retiree who owned rental property destroyed by a tornado and is no longer receiving rental income.

7. Loss of pension income

If your pension is reduced or terminated (for example, because the employer's pension plan was terminated and you are now receiving a reduced PBGC benefit), you can request reconsideration. A simple decision to stop taking pension distributions you are entitled to does not qualify.

8. Employer settlement payment

If you received a settlement payment from your former employer that produced unusually high income in the look-back year, and that payment will not recur, you may qualify for reconsideration. This typically arises in cases of severance, deferred compensation lump sums, or employer plan settlements.

What does NOT qualify as a life-changing event

  • Selling stock, real estate, or a business voluntarily (capital gains)
  • Roth IRA conversions
  • Required Minimum Distributions
  • Inheritance (although inheritance does not affect MAGI directly except for any taxable income generated)
  • A spouse retiring while you continue working (you can still file SSA-44 for your own work stoppage when that happens)
  • A year-end bonus or unusually high earned income
  • A windfall from a lottery or settlement that is unrelated to your employer

How to file SSA-44

The form is available at ssa.gov/forms/ssa-44.pdf. You can submit it by mail, by fax, or in person at your local Social Security field office. Georgia has field offices throughout the state including Atlanta, Augusta, Columbus, Macon, Savannah, Athens, Albany, Valdosta, and Gainesville. The form requires you to document the life-changing event, provide evidence (marriage certificate, death certificate, employer letter, etc.), and provide an estimate of your projected MAGI for the year you are asking SSA to use.

SSA typically responds within 60 to 90 days. If approved, SSA will adjust your premium retroactively to the month the life-changing event occurred (or to the start of the IRMAA year, depending on the event). If denied, you have appeal rights to an Administrative Law Judge, the Appeals Council, and then federal district court under 42 USC 405(g).

How Part B IRMAA is collected versus how Part D IRMAA is collected

This distinction trips up many beneficiaries.

Part B IRMAA is withheld from your Social Security check, the same way the standard Part B premium is withheld. If you receive a Social Security benefit of $3,200 per month and your 2026 Part B premium (standard plus IRMAA) is $480.20, SSA will withhold the full $480.20 from your monthly Social Security payment, leaving you with $2,719.80. If your Social Security benefit is not large enough to cover the premium, or you are not yet collecting Social Security, Medicare will direct-bill you quarterly through the Medicare Premium Bill (CMS-500).

Part D IRMAA is different. The Part D base premium (typically $30 to $60 per month depending on the plan) is paid to your Part D plan, often automatically deducted from your Social Security check at your request. But the Part D IRMAA portion is direct-billed by Medicare itself, regardless of whether your Part D plan is a standalone Prescription Drug Plan or bundled inside a Medicare Advantage MA-PD plan. You will receive a quarterly bill (CMS-500) from Medicare for the Part D IRMAA component. You can also choose to have the Part D IRMAA withheld from Social Security to consolidate the billing.

Failure to pay Part D IRMAA is treated as failure to pay the Part D premium. After several months of nonpayment, your Part D coverage can be terminated and you can be subject to a Late Enrollment Penalty when you re-enroll. This is a real risk for high-income beneficiaries who do not realize they have a separate Part D IRMAA bill arriving in addition to whatever they pay their MA-PD or PDP plan. The first place to check is the Medicare Premium Bill (CMS-500). If you have one, the IRMAA component will appear as a separate line item.

The hold-harmless limitation: who benefits and who does not

Section 1839(f) of the Social Security Act includes a hold-harmless provision that limits the Part B premium increase for certain beneficiaries when the Social Security cost-of-living adjustment is small relative to the premium increase. The provision is designed to ensure that no Social Security beneficiary sees a net decrease in their monthly Social Security check from one year to the next due to a Part B premium increase.

The hold-harmless rule applies to beneficiaries who:

  1. Have their Part B premium withheld from their Social Security benefit, and
  2. Are not subject to IRMAA (i.e., they pay only the standard Part B premium).

The rule does NOT apply to:

  1. New Medicare enrollees who did not pay a Part B premium in the prior year,
  2. Beneficiaries who do not yet collect Social Security,
  3. Beneficiaries who are subject to IRMAA, or
  4. Medicare-Medicaid dually eligible beneficiaries whose Part B premium is paid by the state.

The exclusion of IRMAA payers means high-income beneficiaries do not benefit from hold-harmless protection. If COLA is small in a given year and the standard Part B premium increases, IRMAA payers absorb the full increase plus the proportional IRMAA adjustment. This is a structural feature of the IRMAA framework that Congress has not revisited since 2003.

IRMAA and Medicare Savings Programs and Extra Help: who can qualify

In theory, IRMAA payers and Medicare Savings Program (MSP) enrollees are mutually exclusive populations. MSPs (the Qualified Medicare Beneficiary, Specified Low-Income Medicare Beneficiary, and Qualifying Individual programs) pay the Part B premium for beneficiaries with very low income (generally under approximately $1,500 per month for an individual in 2026). IRMAA applies to beneficiaries with very high income. The two groups do not overlap in normal cases.

However, there are unusual scenarios where someone who paid IRMAA in a prior year subsequently qualifies for MSP. A common example: a surgeon who retires, has a high MAGI in the look-back year that triggers IRMAA, then has very modest retirement income for a few years before becoming eligible for QMB or SLMB due to a combination of low income and depleted assets. The IRMAA recalculates automatically based on the new tax returns, and the MSP eligibility kicks in separately based on the current monthly income and asset test. There is no procedural conflict between the two programs.

The Extra Help program (the Part D Low-Income Subsidy) similarly is targeted at low-income beneficiaries. Extra Help recipients pay no Part D premium and no Part D IRMAA. If a beneficiary previously paid Part D IRMAA and then qualified for Extra Help, the Part D IRMAA stops immediately upon Extra Help approval. The Inflation Reduction Act expanded Extra Help eligibility to 150 percent of the federal poverty level effective January 1, 2024, which moved more lower-middle-income beneficiaries into the program. None of those beneficiaries are subject to IRMAA.

Appeal rights: what to do when SSA says no

If SSA denies your SSA-44 reconsideration request, you have a tiered appeal process. The process is described in 20 CFR 418.1301 and following sections.

Step 1: Reconsideration by SSA

The SSA-44 itself is the reconsideration request. If SSA denies it (typically a written notice explaining which element of the life-changing event was not established), you have 60 days to request the next step.

Step 2: Administrative Law Judge (ALJ) hearing

You file a Request for Hearing by Administrative Law Judge (Form HA-501) within 60 days of the SSA denial. The ALJ hearing is conducted under the SSA Office of Hearings Operations process. You can appear in person, by phone, or by video. You can be represented by an attorney, an accredited representative, or a family member. The ALJ issues a written decision typically within 90 to 180 days.

Step 3: Appeals Council

If the ALJ rules against you, you can request review by the SSA Appeals Council (Form HA-520) within 60 days. The Appeals Council can affirm, reverse, or remand. Most requests are denied without a substantive review.

Step 4: Federal District Court

If the Appeals Council denies review or rules against you, you can file a civil action in the United States District Court for the district where you live. For most Georgia residents this is the Northern District of Georgia (Atlanta), the Middle District of Georgia (Macon), or the Southern District of Georgia (Savannah). The filing is governed by 42 USC 405(g). The court reviews the SSA record for whether the agency's decision was supported by substantial evidence and based on the correct legal standard. Successful federal appeals are uncommon but do happen, typically where SSA misinterpreted the eight life-changing event categories.

Most IRMAA appeals end at the SSA reconsideration or ALJ stage. The cost-benefit of carrying an appeal forward depends on the dollar amount at stake and the strength of your evidence. A retiree with a one-year IRMAA exposure of $4,000 generally does not pursue federal court litigation, but the same retiree might if the issue would recur for multiple years (for example, a contested employer settlement payment that affects multiple look-back years).

Tax planning strategies to manage IRMAA

The cliff structure of IRMAA brackets makes year-end income management one of the highest-return planning activities in retirement. A single planning move that keeps MAGI under a bracket boundary can save thousands of dollars in premiums two years later. Strategies that Georgia retirees commonly use include:

Roth conversions in low-income years before Medicare eligibility

The years between retirement and the start of Medicare (typically ages 62 to 64) are often the lowest-income years of an entire lifetime. Wages have ended, Social Security has not yet started, and required minimum distributions are years away. A retiree can convert traditional IRA balances to Roth in these years, paying federal income tax at relatively low marginal rates, with the converted amount fully taxable in the year of conversion. Because Medicare begins at 65, conversions completed by age 63 do not affect IRMAA (the two-year look-back means age 63 income drives age 65 premiums, and there is no IRMAA at age 65 if MAGI is below the threshold in age 63). Roth conversions completed at age 63 or later do affect IRMAA two years later.

Spreading large conversions across multiple years

A retiree with $1.5 million in a traditional IRA who wants to convert most of it to Roth can do so in a single year (with one bad IRMAA year two years later, likely at the top tier) or spread across five years (with five years of moderate IRMAA exposure, likely tiers 1 or 2). The cumulative IRMAA cost is usually lower with the spread approach. A typical calculation in a five-year conversion plan looks at the marginal federal tax rate of each conversion bracket, the IRMAA exposure of each MAGI bracket, the Georgia state income tax (6 percent), and the time value of money on the Roth growth.

Qualified Charitable Distributions

A QCD from a traditional IRA directly to a qualifying charity excludes the distributed amount from gross income up to $108,000 per individual in 2026. The QCD satisfies the RMD requirement, which means the RMD does not flow through AGI. For charitably inclined retirees with large traditional IRA balances, the QCD is one of the most powerful IRMAA tools available. A retiree with a $90,000 RMD who wants to donate $90,000 to their church or to Brevy's community partners can use a QCD to do both the RMD and the donation in a single transaction without increasing MAGI.

Capital gain harvesting

Selling appreciated assets in a year when you are close to but below the next IRMAA bracket can be timed to optimize. The 0 percent long-term capital gains rate applies to MAGI under $48,350 single or $96,700 MFJ in 2025, which most Medicare beneficiaries are above. But the IRMAA bracket boundaries still matter. Harvesting gains in lower-income years rather than RMD years can prevent stacking.

Tax-loss harvesting

Realizing capital losses in years when you have offsetting gains, or carrying losses forward, can reduce MAGI in IRMAA-sensitive years. Pair this with the cliff structure: a $5,000 loss harvested in November can keep MAGI just under the bracket boundary and save a full year of IRMAA.

Charitable bunching with a donor-advised fund

A retiree who normally donates $20,000 per year can bunch five years of donations ($100,000) into a single year using a donor-advised fund, taking a large itemized deduction in the bunching year and using the standard deduction in subsequent years. This does not affect MAGI directly (it reduces taxable income but not AGI), but it interacts with planning around large IRA-to-Roth conversions or other taxable events.

HSA contributions through age 65

HSAs are not available after Medicare enrollment, but in the years before Medicare a working retiree on a high-deductible health plan can contribute to an HSA. HSA contributions reduce AGI dollar-for-dollar and therefore reduce MAGI. Contributions stop in the month Medicare begins.

Health Reimbursement Arrangements

For retirees who are still working and have access to an HRA, certain HRA structures reduce taxable income without affecting MAGI. The interaction with IRMAA is complex and worth a tax adviser's review.

Income smoothing in self-employment

A self-employed retiree with discretion over the timing of invoicing and expense recognition can spread income across the year-end boundary to avoid cliffs. Defer December invoicing to January if you are close to a bracket. Accelerate January expenses to December if you are over a bracket and want to avoid the next tier.

Six worked examples for Georgia retirees

Example 1: Margaret, age 72, Atlanta, IRMAA tier 1, $115,000 MAGI from RMDs

Margaret is a retired Atlanta Public Schools librarian living in Brookhaven. She is single, owns her home outright, and has a $1.4 million traditional IRA from a rollover of her 403(b). Her Social Security benefit is $2,800 per month ($33,600 per year). Her 2024 RMD on the IRA was approximately $58,000. Her 2024 MAGI totaled approximately $115,000 ($33,600 Social Security taxable portion + $58,000 RMD + $23,000 other taxable income from a small annuity). In 2026 she pays IRMAA tier 1.

Her 2026 Part B premium is $259.00 per month ($74.00 IRMAA above standard $185.00). Her Part D IRMAA is $13.70 per month. Annual additional cost: ($74.00 + $13.70) × 12 = $1,052.40 above what she would pay at standard premium.

Margaret's planning options:

  • Use QCDs to satisfy her RMD without flowing it through AGI. If she directs $58,000 to qualifying charities directly from the IRA, her MAGI drops by $58,000 to approximately $57,000, putting her below the $103,000 threshold. She would owe no IRMAA in 2028 (based on 2026 income).
  • Bunch charitable giving across multiple years using a donor-advised fund.
  • Consider tax-loss harvesting in any taxable brokerage account.

Margaret talks to her tax preparer about QCDs. The QCD is set up for 2026 to charities including the Atlanta Community Food Bank, her local church, and a memorial scholarship. This eliminates her IRMAA exposure starting in 2028.

Example 2: Robert and Susan, ages 70 and 68, Augusta, IRMAA tier 2, $300,000 MAGI from business sale

Robert and Susan are a married couple in Augusta. Robert retired from a regional bank in 2023. In 2024 they sold a commercial rental property that Susan had inherited from her parents, generating a long-term capital gain of $220,000. Their other 2024 income was $80,000 (Social Security plus pensions plus modest IRA withdrawals). Their 2024 MFJ MAGI was $300,000. In 2026 they pay IRMAA tier 2 (MFJ threshold $258,001 to $322,000).

Their 2026 Part B premium is $369.40 per month per spouse ($184.40 IRMAA above standard). Combined Part B IRMAA cost: $184.40 × 2 × 12 = $4,425.60 per year. Add Part D IRMAA: $35.30 × 2 × 12 = $847.20 per year. Total combined IRMAA exposure for 2026: $5,272.80.

This is a one-time spike. Their 2025 income returns to approximately $80,000. In 2027, IRMAA will recalculate based on 2025 MAGI and they will be back to standard premiums. The 2024 property sale created one bad IRMAA year (2026), and they cannot file SSA-44 because a voluntary property sale is not a qualifying life-changing event. Robert and Susan plan to accept the 2026 IRMAA as the cost of the sale. If they had known in advance, they might have considered an installment sale to spread the gain across multiple years.

Example 3: James, age 68, Macon, work stoppage SSA-44 reconsideration

James was the chief financial officer of a Macon manufacturing firm. His 2024 W-2 income was $280,000. He retired on December 31, 2024 at age 67. He started Medicare at age 65 in 2022 and has been on Original Medicare with a Medigap policy. His 2025 income is approximately $90,000 (Social Security plus pension plus modest IRA withdrawals). His 2026 income will be similar.

Without SSA-44, his 2026 IRMAA would be based on 2024 MAGI of $280,000, putting him in tier 3 ($193,001 to $499,999 single). His combined annual IRMAA exposure would be approximately $5,815 ($484.60 × 12).

James files SSA-44 in January 2026, documenting his work stoppage with a letter from his former employer confirming the December 31, 2024 retirement date, his W-2 history, and his projected 2026 MAGI of $90,000. He attaches an estimate showing 2026 MAGI well below the $103,000 single threshold. SSA approves the reconsideration in March 2026 and adjusts his 2026 premium to standard, with a retroactive refund for January and February.

James saves approximately $5,815 in 2026. The same SSA-44 will not be needed for 2027 because the regular annual recalculation will use his 2025 tax return, which will reflect his post-retirement income directly.

Example 4: Patricia, age 75, Savannah, widow SSA-44 reconsideration

Patricia's husband died on March 15, 2025. Their 2024 MFJ tax return showed MAGI of $280,000, driven primarily by her husband's W-2 income as a Savannah hospital administrator and a partial Roth conversion. Patricia's individual income post-death is approximately $85,000 (Social Security survivor benefit, pension survivor benefit, modest IRA withdrawals).

Without SSA-44, Patricia's 2026 IRMAA would be based on the MFJ 2024 return, applying the single-filer thresholds because she would be filing as single or qualifying widow in 2026. With MAGI of $280,000 and single thresholds, she would pay tier 4 IRMAA. Annual cost: approximately $5,815.

Patricia files SSA-44 documenting her husband's death (death certificate) and her projected single-filer 2026 MAGI of $85,000. SSA approves and adjusts her 2026 premium to standard. The reconsideration takes about 60 days.

The widow scenario is especially important because the survivor often does not realize that the joint return filed for the year of death will drive a high IRMAA two years later. Filing SSA-44 promptly after the spouse's death is one of the most important administrative tasks for a Georgia widow or widower whose joint income was substantial.

Example 5: Charles, age 80, Columbus, capital gains spike from Roth conversion

Charles is a retired civil engineer in Columbus with a $2.8 million traditional IRA. His financial adviser recommended a five-year Roth conversion plan. In 2024 Charles converted $250,000. His other income was $90,000 (Social Security plus pension). His 2024 MAGI was $340,000. In 2026 he pays IRMAA tier 4 ($193,001 to $499,999 single).

Annual 2026 IRMAA exposure: approximately $5,815.

Charles's adviser had explicitly modeled the IRMAA cost as part of the conversion plan. The total five-year cost of IRMAA (five separate one-year exposures, each driven by a conversion year MAGI of approximately $340,000) is approximately $29,075 cumulative. Against that, the conversion moves $1.25 million from a tax-deferred account (where future withdrawals would have been taxable at potentially higher rates and would have flowed through MAGI and driven future IRMAA) to a Roth account (tax-free withdrawals, no MAGI impact). The five-year IRMAA cost is part of the total cost of the conversion strategy, and Charles's adviser concluded the strategy was net positive given his particular tax and estate planning goals.

Charles cannot file SSA-44 for the Roth conversion because conversions are not qualifying life-changing events. He accepts each year's IRMAA as a planned cost.

Example 6: Linda, age 67, Atlanta, MFS filing status IRMAA cliff

Linda lives in Atlanta and is in the process of separating from her spouse but has not filed for divorce. For 2024 she filed Married Filing Separately because of complications with her spouse's tax situation. Her 2024 MAGI as MFS was $110,000. Under the MFS thresholds, MAGI above $106,000 jumps directly to IRMAA tier 4. Her 2026 Part B premium is $590.60 per month, an increase of $405.60 over standard. Annual Part B IRMAA cost: $4,867.20. Plus Part D IRMAA: $943.20. Total: $5,810.

Linda's MFS filing status was a non-IRMAA choice driven by her spouse's tax situation, but it produces a punishing IRMAA outcome. The MFS structure is statutory and there is no SSA-44 event for "I would have paid less if I had filed jointly." Linda's options:

  • File jointly for 2025 if her spouse is willing. Joint MAGI of approximately $200,000 (her $110,000 plus his $90,000) would fall below the $206,000 MFJ threshold, eliminating 2027 IRMAA entirely.
  • Amend the 2024 return to joint filing if both spouses agree. This is possible up to three years after the original due date.
  • After divorce in 2026, file as single in 2026 and have IRMAA drop to single thresholds for 2028 onward.

Linda consults with a CPA and a divorce attorney. The eventual decision is to file jointly for 2025 (her spouse agrees, given the family financial benefit), and to expedite the divorce filing so that 2026 is filed as single.

How Georgia retirees can use IRMAA exposure as an opportunity

Paying IRMAA is not necessarily bad. Many of the situations that produce IRMAA exposure (large Roth conversion, sale of an appreciated business, capital gain harvesting, high working income) are actually good things from a long-term wealth planning perspective. The IRMAA surcharge is the marginal cost of those transactions. A planning question is rarely "how do I avoid IRMAA at all costs" but rather "given my goals, how do I minimize the IRMAA component while still accomplishing what I need to accomplish."

A typical Brevy-recommended sequence for a Georgia retiree thinking about IRMAA:

  1. Inventory your 2024 tax return MAGI components. Know your AGI, your tax-exempt interest, and any foreign earned income exclusion. Add them. That is your IRMAA MAGI.

  2. Project your 2025 and 2026 MAGI under your current plan. Will RMDs increase? Will pensions adjust? Are there planned Roth conversions or asset sales?

  3. Identify which IRMAA bracket you are likely to fall into for 2026, 2027, and 2028. Each year is independent.

  4. Identify cliffs. Are you within $5,000 of the next bracket up or down? If so, year-end income management may pay for itself many times over.

  5. Evaluate SSA-44 eligibility. Have you had a life-changing event in the past 18 months? File the form promptly.

  6. Build a long-term plan. Roth conversions over multiple years, QCDs to satisfy RMDs, charitable bunching with a donor-advised fund, capital gain timing, and HSA contributions before Medicare all interact.

  7. Re-check every year. IRMAA recalculates annually. The plan should be reviewed annually with the most recent SSA initial determination notice and the most recent tax return.

Common Georgia errors and how to avoid them

Error 1: Not filing SSA-44 promptly after retirement. Many Georgia retirees do not know SSA-44 exists. They start paying IRMAA based on their final working-year income and assume it is permanent. The reconsideration is available within the same year the work stoppage occurred. Filing in January after a December retirement is ideal.

Error 2: Treating municipal bond interest as exempt for IRMAA. Georgia retirees often hold large municipal bond portfolios. The tax-exempt interest is added back to AGI for IRMAA MAGI under Section 1839(i)(4). Many retirees do not realize this until they receive their first IRMAA notice.

Error 3: Ignoring the cliff structure. A retiree who is $200 over a bracket pays the same IRMAA as a retiree who is $30,000 over. Year-end income management is high-value.

Error 4: Forgetting that Roth conversions count. Conversion amounts flow through AGI in the year of conversion and drive IRMAA two years later. Spreading conversions across multiple years often reduces total IRMAA cost.

Error 5: Filing MFS during Medicare years without understanding the IRMAA consequence. The MFS thresholds are compressed and the surcharge jumps quickly to the top tier. Avoid MFS unless required.

Error 6: Not paying the Part D IRMAA bill. The Part D IRMAA arrives as a separate bill from Medicare even if your Part D plan is bundled with Medicare Advantage. Failure to pay can result in Part D termination and a Late Enrollment Penalty.

Error 7: Missing the SSA-44 supporting documentation. The form requires substantial documentation. An employer letter confirming retirement, a death certificate, a marriage certificate, or evidence of loss is essential. SSA denies forms that are incomplete or missing documentation.

Error 8: Believing IRMAA is permanent. It is not. It resets every year based on the most recent tax return. A one-time high-income event creates one bad IRMAA year, not a lifetime of high premiums.

Error 9: Not appealing a denied SSA-44. SSA reconsideration is the first level. ALJ hearings result in reversal in a meaningful percentage of cases where the underlying life-changing event is well-documented but SSA's initial reviewer applied an overly strict standard.

Error 10: Confusing IRMAA with the Late Enrollment Penalty. They are separate. The LEP is a permanent monthly addition for late Part B or Part D enrollment. IRMAA is an income-based annual surcharge. A beneficiary can pay both at the same time.

Error 11: Not coordinating with the year-end tax plan. IRMAA is one of many things to balance at year-end. A tax-loss harvest, a QCD, an HSA contribution, or a deferred bonus may each shift the IRMAA outcome.

Error 12: Missing the 60-day appeal window. Each appeal level has a 60-day window from the prior decision. Missing the window typically forfeits the appeal.

Error 13: Not consolidating Part D IRMAA into Social Security withholding. Beneficiaries can opt to have Part D IRMAA withheld from their Social Security check rather than direct-billed. This avoids the risk of missing the quarterly Medicare Premium Bill.

Error 14: Assuming a tax adviser knows IRMAA. Many tax preparers focus on minimizing federal income tax and do not optimize separately for IRMAA. Ask your preparer specifically about IRMAA bracket boundaries when you plan a Roth conversion or large income event.

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Frequently Asked Questions

What is IRMAA in plain language?

IRMAA stands for Income-Related Monthly Adjustment Amount. It is the federal surcharge that high-income Medicare beneficiaries pay on top of the standard Part B and Part D premium. The surcharge was established by Section 1839(i) of the Social Security Act for Part B (effective January 1, 2007) and by Section 1860D-13(a)(7) for Part D (effective January 1, 2011). About 7 to 8 percent of Medicare beneficiaries nationally pay IRMAA, which translates to roughly 130,000 to 150,000 Georgia beneficiaries.

Why does my IRMAA in 2026 depend on my 2024 tax return?

Social Security uses a two-year look-back to determine IRMAA. The IRS needs time to process returns, and SSA needs time to set premiums for the upcoming year. The most recent return available to SSA when it sets premiums for the next calendar year is the return from two years earlier. So your 2024 Modified Adjusted Gross Income drives your 2026 IRMAA. The look-back is mandated by Section 1839(i) and 20 CFR 418 Subpart B.

How is Modified Adjusted Gross Income (MAGI) calculated for IRMAA?

MAGI for IRMAA purposes equals Adjusted Gross Income from Form 1040 Line 11, plus tax-exempt interest from Form 1040 Line 2a, plus any excluded foreign earned income under IRC Section 911. It does not include Roth IRA distributions (those are not in AGI) but does include Roth conversion amounts (those are in AGI in the conversion year). It does not include Social Security benefits beyond the taxable portion already in AGI.

What are the 2026 IRMAA income brackets for a single filer?

For 2026 (based on 2024 MAGI for a single filer or head of household): standard premium up to $103,000; tier 1 from $103,001 to $129,000; tier 2 from $129,001 to $161,000; tier 3 from $161,001 to $193,000; tier 4 from $193,001 to $499,999; tier 5 at $500,000 or more.

What are the 2026 IRMAA income brackets for a married couple filing jointly?

The MFJ thresholds are double the single thresholds: standard up to $206,000; tier 1 $206,001 to $258,000; tier 2 $258,001 to $322,000; tier 3 $322,001 to $386,000; tier 4 $386,001 to $749,999; tier 5 $750,000 or more.

Why is Married Filing Separately so much worse for IRMAA?

The MFS structure was set in statute and never updated. The MFS threshold is approximately $106,000. Above that, the beneficiary jumps directly to tier 4. The reason is that MFS is generally treated as a non-standard filing election, and Congress did not write phased tiers for MFS taxpayers. A married couple filing separately with each spouse just above $106,000 will pay approximately $11,630 combined in 2026 IRMAA. The same couple filing jointly with combined MAGI of $220,000 would pay no IRMAA.

How is Part B IRMAA collected?

Part B IRMAA is withheld from your Social Security check, the same way the standard premium is. If your Social Security is not large enough, Medicare direct-bills you quarterly through the CMS-500 Medicare Premium Bill.

How is Part D IRMAA collected?

Part D IRMAA is direct-billed by Medicare itself, regardless of whether your Part D plan is standalone or bundled inside Medicare Advantage. You can elect to have the bill withheld from Social Security instead. Failure to pay Part D IRMAA can result in Part D termination and a Late Enrollment Penalty.

Can I file Form SSA-44 if I had a Roth conversion this year?

No. Roth conversions are not qualifying life-changing events. The eight events are death of spouse, marriage, divorce or annulment, work stoppage, work reduction, loss of income-producing property, loss of pension income, and employer settlement payment. Voluntary financial transactions including conversions, asset sales, RMDs, and bonuses do not qualify.

What documentation do I need for a work stoppage SSA-44?

You need a letter from your former employer confirming the date you stopped working (or evidence of retirement from self-employment), your most recent W-2 or 1099, evidence of pension or Social Security commencement if applicable, and an estimate of your projected MAGI for the year SSA will use for the recalculation.

How long does SSA take to decide an SSA-44 reconsideration?

Typically 60 to 90 days. SSA may request additional documentation. If you have not heard back after 90 days, you can call 1-800-772-1213 or visit your local field office.

What if SSA denies my SSA-44?

You have 60 days to file Form HA-501 to request an Administrative Law Judge hearing. The ALJ hearing is typically scheduled 90 to 180 days out. If the ALJ rules against you, you can appeal to the SSA Appeals Council (Form HA-520) and then to federal district court under 42 USC 405(g).

Does my Social Security taxable amount count toward IRMAA MAGI?

Only the portion of Social Security that is already taxable and flowing through AGI counts. The nontaxable portion does not. Social Security taxation depends on combined income and ranges from 0 to 85 percent of benefits being taxable.

What is the hold-harmless rule and does it apply to me?

The hold-harmless rule under Section 1839(f) limits Part B premium increases for beneficiaries who have their premium withheld from Social Security and who are not subject to IRMAA. If COLA is small relative to the premium increase, hold-harmless protects the net Social Security check from declining. IRMAA payers are explicitly excluded.

Do I pay IRMAA if I am on Medicare Advantage?

Yes. IRMAA applies to your Part B premium regardless of whether you are on Original Medicare or Medicare Advantage. If you are on Medicare Advantage with a Part D component (MA-PD), the Part D IRMAA also applies and is direct-billed by Medicare separately from any premium you pay to the MA plan.

Do I pay IRMAA if I have Medigap coverage?

Yes. Medigap is supplemental and does not affect your Part B premium. IRMAA applies to the Part B premium directly.

Will IRMAA increase my Medicare Supplement premium?

No. Medigap premiums are set by the insurance carrier and are not based on income. IRMAA is a federal surcharge on the federal Part B premium only.

Can I avoid IRMAA by deferring Social Security?

Deferring Social Security does not affect IRMAA directly. IRMAA is determined by MAGI, not by whether you are collecting Social Security. Deferring Social Security may increase your eventual Social Security benefit, but it does not reduce IRMAA.

What is the difference between IRMAA and the Late Enrollment Penalty?

They are entirely separate. The LEP is a permanent monthly addition for late Part B or Part D enrollment, calculated based on how many months you went without coverage. IRMAA is an annual income-based surcharge. You can pay both at the same time.

How can I project my future IRMAA?

Project your future MAGI year by year. Account for RMDs (starting at age 73), Social Security, pension income, IRA withdrawals, dividends, interest including tax-exempt interest, capital gains, and any planned Roth conversions. Compare to the IRMAA brackets. For most retirees, the years where RMDs and other income coincide are the worst IRMAA years.

Should I do a Roth conversion if it triggers IRMAA?

Maybe. The IRMAA cost is one factor in a Roth conversion decision. Other factors include the federal and state marginal tax rate at conversion, the projected future tax rate on Roth withdrawals, estate planning goals, and the size of the IRA. A typical analysis spreads conversions across multiple years to minimize IRMAA cliff effects while still achieving the conversion goal.

Does selling my house trigger IRMAA?

Possibly. Long-term capital gain on a primary residence is excluded up to $250,000 single or $500,000 MFJ under IRC Section 121. Gains above that exclusion are included in AGI and drive MAGI. Selling a second home or a rental property generates fully taxable capital gain.

Does a Qualified Charitable Distribution reduce IRMAA?

Yes. A QCD from a traditional IRA directly to a qualifying charity (up to $108,000 per individual in 2026) is excluded from gross income, satisfies the RMD requirement, and does not flow through AGI. This is one of the most powerful IRMAA tools for charitably inclined retirees.

What if I am dually eligible for Medicare and Medicaid?

Dual eligibles whose Part B premium is paid by Medicaid through a Medicare Savings Program do not pay IRMAA out of pocket. The state pays the premium. In practice, dually eligible beneficiaries have very low income and would not be in an IRMAA bracket anyway.

Where can I get help with IRMAA in Georgia?

GeorgiaCares SHIP at 1-866-552-4464 offers free Medicare counseling including IRMAA help. The Social Security Administration at 1-800-772-1213 handles SSA-44 filings. Local Social Security field offices can take SSA-44 in person. A tax adviser or CPA can help with the tax planning side. Brevy at brevy.com publishes regularly updated guides. :::

How IRMAA fits into the broader Medicare premium framework

It helps to see IRMAA in context. The standard Part B premium of $185 per month covers approximately 25 percent of the average per-capita Part B cost. The remaining 75 percent comes from federal general revenues. IRMAA shifts the percentage upward for higher-income beneficiaries. At tier 5, the beneficiary pays approximately 85 percent of per-capita Part B cost, with the federal subsidy reduced to about 15 percent.

For Part D, the standard structure is similar. The Part D base beneficiary premium reflects approximately 25.5 percent of expected Part D cost, with the remaining 74.5 percent covered by direct federal subsidies. Part D IRMAA increases the beneficiary share to approximately 85 percent at tier 5, again shifting the subsidy structure for high-income beneficiaries.

The IRMAA framework therefore is best understood as a progressive premium structure inside an otherwise flat-premium program. It is unusual in the United States health insurance landscape, which generally does not use income-based premium tiers. Medicare's IRMAA structure has been studied extensively and has held up to constitutional and statutory challenges. The framework is now a settled feature of the Medicare program for high-income beneficiaries.

A note on the Inflation Reduction Act and IRMAA

The Inflation Reduction Act of 2022, Public Law 117-169, made significant changes to Medicare Part D. The most relevant changes for IRMAA payers are:

  1. The new $2,000 annual out-of-pocket cap on covered Part D drugs effective January 1, 2025. This cap applies to all Part D enrollees, including IRMAA payers, and substantially reduces drug cost exposure.
  2. The Medicare Drug Price Negotiation Program, which is producing negotiated prices for the first ten selected Part B and Part D drugs effective January 1, 2026, and additional drugs in subsequent years.
  3. Expansion of Extra Help eligibility to 150 percent of the federal poverty level effective January 1, 2024.
  4. Limits on Part D plan premium increases.

None of these provisions change the IRMAA brackets directly. IRMAA continues to operate under Section 1839(i) and Section 1860D-13(a)(7) with the existing bracket structure. The interaction is indirect: the $2,000 out-of-pocket cap reduces the value differential between Part D plans, and the negotiated prices reduce average per-beneficiary Part D cost over time, which feeds into the underlying premium calculation that IRMAA percentages are applied to.

Working with Brevy on IRMAA planning

Brevy publishes regularly updated guides on Medicare, Medicaid, IRMAA, and related topics at brevy.com. We do not provide tax or legal advice. We do provide research-grade content that explains the framework, the dollar amounts, and the strategies in plain language so that Georgia families can make informed decisions in consultation with their tax adviser, financial planner, and legal counsel.

For free Medicare counseling specifically about IRMAA, contact the GeorgiaCares State Health Insurance Assistance Program at 1-866-552-4464. SHIP counselors are trained in Medicare and can help with SSA-44 preparation.

For tax planning, work with a CPA or Enrolled Agent who has experience with Medicare-aged clients. Look for a tax professional who can model IRMAA bracket boundaries alongside federal and state income tax brackets.

For legal questions about Medicare appeals, contact Atlanta Legal Aid at 404-377-0701, Georgia Legal Services at 1-800-498-9469, or the Center for Medicare Advocacy at 1-860-456-7790.

For Social Security questions and SSA-44 filing, contact the Social Security Administration at 1-800-772-1213 or visit your local field office. Office locations are at ssa.gov/locator.

Disclaimers

This article is for educational purposes only and does not constitute tax, legal, financial, or medical advice. IRMAA brackets, dollar amounts, and rules are subject to change. The dollar amounts in this article reflect 2026 CMS-published figures as of May 2026 and may be updated by CMS. Always verify the current bracket amounts at medicare.gov or with a qualified tax adviser before making planning decisions.

Brevy is not affiliated with the Centers for Medicare and Medicaid Services, the Social Security Administration, the Internal Revenue Service, the U.S. Department of the Treasury, the Georgia Department of Community Health, or any other federal or state agency. Brevy is an eldercare research and information company. We accept no compensation from insurance carriers, plan sponsors, or other parties whose products or services we may discuss.

Information about specific Georgia agencies, courts, hospitals, post-acute providers, and counselors reflects publicly available information as of the publication date. Provider participation, contact numbers, and program features may change. Verify current information directly with the relevant organization before relying on it.

This article was researched and written by the Brevy Care Team and is pending final editorial review.

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Get help with IRMAA in Georgia

Federal agencies

  • Social Security Administration: 1-800-772-1213 (TTY 1-800-325-0778). Handles SSA-44 filings, Medicare enrollment, and Part B premium questions. ssa.gov
  • Medicare: 1-800-MEDICARE (1-800-633-4227). General Medicare questions and Part D IRMAA billing. medicare.gov
  • Internal Revenue Service: 1-800-829-1040. Federal tax questions including Modified Adjusted Gross Income. irs.gov
  • Centers for Medicare and Medicaid Services (CMS): cms.gov for premium and IRMAA bracket announcements

Georgia state agencies

  • GeorgiaCares SHIP (State Health Insurance Assistance Program): 1-866-552-4464. Free Medicare counseling. Helps with IRMAA, SSA-44, plan selection, and appeals. georgiacares.org
  • Georgia Department of Community Health, Medicaid Member Services: 1-866-211-0950. Medicaid and dual-eligibility questions
  • Georgia Department of Insurance: 404-656-2070. Insurance regulation and consumer assistance
  • Georgia Department of Human Services, Division of Aging Services: 1-866-552-4464. Senior services coordination

Local Social Security field offices

  • Atlanta (Main Office): 401 W. Peachtree Street NW, Atlanta, GA 30308
  • Augusta: 4302 University Parkway, Augusta, GA 30907
  • Macon: 2090 Riverside Drive, Macon, GA 31204
  • Savannah: 410 Mall Boulevard, Savannah, GA 31406
  • Columbus: 7263 Schomburg Road, Columbus, GA 31909
  • Locate your nearest office: ssa.gov/locator
  • Atlanta Legal Aid Society: 404-377-0701. Free civil legal services. atlantalegalaid.org
  • Georgia Legal Services Program: 1-800-498-9469. Free legal services for low-income Georgians outside metro Atlanta. glsp.org
  • Center for Medicare Advocacy: 1-860-456-7790. National nonprofit specializing in Medicare appeals. medicareadvocacy.org
  • Medicare Rights Center: 1-800-333-4114. National consumer service. medicarerights.org

Additional resources

  • Eldercare Locator: 1-800-677-1116. National service connecting families with local aging resources. eldercare.acl.gov
  • 211 Georgia: Dial 211 from any Georgia phone for community resources
  • National Council on Aging: 1-800-794-6559. ncoa.org

Brevy

Brevy at brevy.com publishes regularly updated guides on Medicare, Medicaid, VA benefits, and caregiving across all 50 states. Our guides are free, advertising-free, and reviewed annually. :::

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Brevy Care Team

Expert eldercare guidance from Brevy's team of healthcare professionals and researchers.