Georgia Medicare IRMAA Guide 2026: Thresholds, Surcharges, Appeals

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The Income-Related Monthly Adjustment Amount (IRMAA) is the federal means-tested supplemental premium that higher-income Medicare beneficiaries pay on top of the standard Medicare Part B and Medicare Part D premiums. IRMAA is based on the beneficiary's Modified Adjusted Gross Income (MAGI) from the tax return filed two years prior to the premium year. For 2026 IRMAA, the Social Security Administration (SSA) uses the 2024 tax return filed in 2025.

IRMAA affects approximately 7-8% of Medicare beneficiaries nationally, which translates to approximately 100,000 to 120,000 Georgia Medicare beneficiaries subject to some IRMAA tier each year. For these beneficiaries, IRMAA represents a substantial annual cost ranging from approximately $1,052/year at Tier 1 to approximately $6,356/year at Tier 5 — in addition to the standard Part B premium of $185.00/month (2026) and the standalone Part D premium.

IRMAA is codified at:

• Section 1839(i) of the Social Security Act — Part B IRMAA
• Section 1860D-13(a)(7) of the Social Security Act — Part D IRMAA
• 42 CFR 408.20 — Part B IRMAA implementing regulations
• 42 CFR 423.286 — Part D IRMAA implementing regulations

IRMAA was created by the Medicare Modernization Act of 2003 for Part B (effective 2007, originally targeting only the highest-income beneficiaries, later expanded under the Affordable Care Act of 2010 to include the current five-tier structure). The ACA also extended IRMAA to Part D premiums, effective 2011.

IRMAA thresholds are indexed annually to inflation. The 2026 thresholds represent approximately a 3% adjustment over 2025 thresholds, reflecting the September 2025 Consumer Price Index for Urban Consumers (CPI-U) inflation rate.

The critical mechanism in IRMAA is the two-year look-back: SSA uses the most recent IRS-confirmed tax return, which is the return filed two years prior to the premium year. A beneficiary who retires in 2024 may still see IRMAA in 2026 based on their 2024 peak-earning year MAGI — even though their 2026 income is much lower. The SSA Form SSA-44 "Medicare Income-Related Monthly Adjustment Amount — Life-Changing Event" form permits reconsideration in these cases, allowing the beneficiary to substitute an estimated current-year MAGI when a qualifying Life-Changing Event has occurred.

For Georgia, IRMAA is concentrated in metro Atlanta (Fulton, DeKalb, Cobb, Gwinnett counties), the coastal areas (Glynn, Chatham counties), and other affluent enclaves. Common Georgia IRMAA scenarios include:

• Recently-retired professionals and executives with two-year-prior MAGI reflecting peak earning years
• Federal retirees from CDC, federal courts, GSA, DoD installations with high final-year salaries
• Business owners with one-time large income events (business sale, large capital gain)
• Roth conversion strategies that temporarily inflate MAGI two years before Medicare eligibility
• High-net-worth retirees with substantial dividend, interest, and capital gains income

This guide explains the federal IRMAA framework, the 2026 thresholds and surcharges, the eight Life-Changing Events and the SSA-44 reconsideration process, the multi-level appeals available when reconsideration is denied, the tax planning implications, and the Georgia-specific operational context.

Callout: Key Takeaways

• What it is: A means-tested supplemental premium added to Medicare Part B and Part D for higher-income beneficiaries.
• Authority: Section 1839(i) SSA (Part B); Section 1860D-13(a)(7) SSA (Part D); 42 CFR 408.20; 42 CFR 423.286.
• MAGI source: Two-year-prior tax return. 2026 IRMAA uses 2024 MAGI.
• 2026 threshold (no IRMAA): Single MAGI ≤ $106,000; married filing jointly MAGI ≤ $212,000.
• 2026 IRMAA tiers: Five tiers, with total monthly add-on ranging from $87.70 (Tier 1) to $529.70 (Tier 5). Annual cost: $1,052 to $6,356 above standard premiums.
• Notification: SSA mails initial IRMAA determination in November based on IRS data, with premiums effective January 1.
• Eight Life-Changing Events (LCEs): Marriage, divorce/annulment, death of spouse, work stoppage, work reduction, loss of income-producing property, loss or reduction of pension, employer settlement payment.
• Reconsideration: SSA Form SSA-44, filed within 60 days of initial determination, permits substituting an estimated current-year MAGI when an LCE has occurred.
• Appeals: Reconsideration → ALJ Hearing → Medicare Appeals Council → Federal District Court.
• Free Georgia help: GeorgiaCares SHIP at 1-866-552-4464 — free, unbiased IRMAA counseling. Atlanta SSA Office of Hearings Operations adjudicates Georgia IRMAA ALJ hearings.

The Federal IRMAA Framework

Statutory and regulatory authority

The IRMAA framework rests on two statutory grants:

Section 1839(i) of the Social Security Act establishes the Part B IRMAA. The statute specifies the income thresholds (in inflation-adjusted dollars), the surcharge amounts (as a percentage of unsubsidized Part B premium), and the use of two-year-prior MAGI from IRS data. CMS and SSA implement this authority at 42 CFR 408.20.

Section 1860D-13(a)(7) of the Social Security Act establishes the Part D IRMAA. The Part D IRMAA structure parallels Part B but uses different (lower) surcharge dollar amounts because Part D premiums are themselves lower than Part B premiums. CMS implements this authority at 42 CFR 423.286.

The original Medicare Modernization Act of 2003 created the first version of Part B IRMAA, effective 2007, with only three tiers and starting at much higher income thresholds. The Affordable Care Act of 2010 expanded IRMAA significantly — adding additional tiers, lowering thresholds, and extending IRMAA to Part D effective 2011. The current five-tier structure dates from the Bipartisan Budget Act of 2018 amendments effective 2019.

Two-year MAGI look-back

The most important operational feature of IRMAA is the two-year MAGI look-back. SSA uses the most recently filed and IRS-confirmed federal tax return, which is the return filed two years before the premium year:

This look-back exists because the IRS doesn't have current-year income data — federal taxes for tax year 2025 are filed in early 2026, and SSA needs to set 2026 premiums in late 2025. The compromise is to use 2024 (the most recently filed and confirmed year) for 2026 premiums.

The two-year look-back has significant consequences for newly-retired beneficiaries. A 65-year-old who retires in 2024 (last year of peak earnings) will see IRMAA in 2026 based on 2024 MAGI — even if their 2026 income is dramatically lower. This is the most common scenario triggering an SSA-44 Life-Changing Event reconsideration request.

What is MAGI for IRMAA purposes?

MAGI for IRMAA purposes is defined at Section 1839(i)(4) SSA and 42 CFR 408.21 as:

Adjusted Gross Income (AGI) from Line 11 of IRS Form 1040 (or equivalent line on other 1040 variants), PLUS:

• Tax-exempt interest income (Line 2a of Form 1040)

That is, IRMAA MAGI includes tax-exempt municipal bond interest, which is excluded from federal taxable income but included in IRMAA MAGI. This is different from MAGI definitions for other federal programs (Medicaid, premium tax credits, traditional IRA deductibility, etc.).

Importantly, IRMAA MAGI does NOT include:

• Social Security benefits (whether taxable or non-taxable portions)
• Distributions from Roth IRAs (assuming they meet qualified distribution rules)
• Inheritance income
• Life insurance proceeds
• Reverse mortgage proceeds

IRMAA MAGI DOES include:

• Wages and self-employment income
• Pension and 401(k)/403(b) distributions
• Traditional IRA distributions
• Required Minimum Distributions (RMDs)
• Roth conversions (the converted amount is fully taxable)
• Capital gains (long-term and short-term)
• Dividend income (qualified and non-qualified)
• Interest income (taxable AND tax-exempt for IRMAA purposes)
• Rental income
• Business income
• Annuity income (taxable portion)

2026 IRMAA thresholds and surcharges

The following table summarizes the 2026 IRMAA thresholds and surcharges (approximate figures; verify current values at medicare.gov):

For married-filing-separately (MFS) beneficiaries who lived with their spouse during the tax year, the thresholds are much lower, with IRMAA Tier 1 typically starting at MAGI above $106,000 and Tier 5 above approximately $403,000 (MFS-specific rates apply).

The Part B IRMAA is a fixed dollar surcharge added to the standard Part B premium. The Part D IRMAA is a fixed dollar surcharge added to whatever the beneficiary's Part D plan premium happens to be — whether MA-PD, standalone PDP, or even a $0-premium plan. (Yes, even a $0-premium Part D plan will collect Part D IRMAA on top.)

The Part D IRMAA is collected by SSA — not by the Part D plan. SSA either deducts the Part D IRMAA from the beneficiary's Social Security benefit or bills the beneficiary directly through Medicare Easy Pay.

Annual SSA notification

SSA mails the initial IRMAA determination notice in mid-November each year for the following premium year. The notice arrives roughly six weeks before the new premiums take effect on January 1.

The notice includes:

• The MAGI SSA used (and the source — typically "IRS data")
• The tax year of that MAGI
• The IRMAA tier
• The Part B IRMAA amount
• The Part D IRMAA amount
• The total monthly additional premium
• Instructions for reconsideration (SSA Form SSA-44) if an LCE has occurred
• The deadline for reconsideration (60 days from the date of the notice)

A beneficiary who has not received an IRMAA notice by early December should call SSA at 1-800-772-1213 to verify status.

The Eight Life-Changing Events (LCEs)

SSA Form SSA-44 — "Medicare Income-Related Monthly Adjustment Amount — Life-Changing Event" — permits reconsideration when the beneficiary has experienced one of eight Life-Changing Events that reduces current-year MAGI below the two-year-prior MAGI level. The eight LCEs:

LCE 1: Marriage

The beneficiary married, and the marriage altered MAGI calculations. Typically applies when:

• A previously single beneficiary married, lowering their per-capita income because the spouse has low or no income
• A change in filing status (e.g., from married-filing-separately to married-filing-jointly) significantly altered MAGI

LCE 2: Divorce or annulment

The beneficiary divorced or had their marriage annulled. Typically reduces MAGI when:

• A higher-earning spouse's income is no longer combined with the beneficiary's
• The beneficiary moves from married-filing-jointly to single status

LCE 3: Death of spouse

The beneficiary's spouse died. This is one of the most common LCEs and is operationally important because it can be combined with other LCE filings (e.g., death + work stoppage).

LCE 4: Work stoppage

The beneficiary or their spouse stopped working. This is the most common LCE triggering SSA-44 reconsideration — recently-retired beneficiaries facing IRMAA based on peak-earning two-year-prior MAGI.

Work stoppage applies when:

• The beneficiary retired
• The beneficiary's spouse retired
• The beneficiary or spouse stopped working due to disability
• The beneficiary or spouse stopped working due to a documented health condition

LCE 5: Work reduction

The beneficiary or their spouse reduced their work hours significantly, resulting in a decrease in MAGI. Applies when:

• Reduction from full-time to part-time
• Reduction in hours per week
• Transition from full-time to consulting

LCE 6: Loss of income-producing property

The beneficiary lost an income-producing asset, other than from sale or transfer. Examples:

• Natural disaster destruction (hurricane, flood, wildfire) of rental property
• Theft or fraud loss of investment account
• Casualty loss of business asset

LCE 7: Loss or reduction of pension income

The beneficiary's pension income was lost or reduced. Examples:

• Employer pension plan terminated or reduced benefits
• Annuity payments stopped or reduced
• Trust distributions stopped or reduced

LCE 8: Employer settlement payment

The beneficiary received a one-time settlement payment from an employer that inflated MAGI in the two-year-prior tax year and is not expected to recur. Examples:

• Severance package
• Wrongful termination settlement
• Stock option exercise as part of separation
• Retention bonus paid before retirement

Documenting LCEs

For an SSA-44 reconsideration to succeed, the beneficiary must provide documentation of the LCE and an estimated current-year MAGI. Typical documentation:

• Work stoppage: Retirement letter, final pay stub, COBRA notification, employer HR confirmation
• Death of spouse: Death certificate
• Marriage / divorce: Marriage certificate or divorce decree
• Work reduction: New employment agreement, updated pay stub showing reduced hours
• Loss of property: Insurance claim documentation, IRS casualty loss documentation
• Pension loss: Plan termination notice, annuity issuer statement
• Employer settlement: Settlement agreement (with confidentiality redactions if applicable)

The beneficiary must also provide an estimated MAGI for the current year (and optionally the next year) supported by reasonable basis — typically a worksheet showing expected income sources.

The SSA-44 Reconsideration Process

Step 1: Receive initial IRMAA determination

SSA mails the initial IRMAA notice in November for the following premium year.

Step 2: Identify a qualifying LCE

Review the eight LCEs and identify which applies. A single beneficiary can submit one SSA-44 covering one LCE — but multiple distinct LCEs can be combined on a single form if they all reduce current-year MAGI.

Step 3: Complete SSA Form SSA-44

The form is available at ssa.gov/forms/ssa-44.pdf. Sections include:

• Beneficiary identifying information
• The qualifying LCE (check the applicable box)
• Date of LCE
• Estimated current-year MAGI (and optionally next year)
• Tax filing status (current year)
• Beneficiary attestation
• Signature

Step 4: Gather documentation

Attach:

• LCE-supporting documents (retirement letter, death certificate, etc.)
• Reasonable basis for estimated MAGI (calculation worksheet, recent paystubs, projected investment income)

Step 5: Submit to local SSA field office

The form can be:

• Filed in person at any of the 27 Georgia SSA field offices
• Mailed (certified mail recommended)
• Faxed (if the local office accepts faxes)
• Sometimes filed online through the beneficiary's my Social Security account

Filing in person is generally preferred because the SSA representative can review the documentation immediately and answer questions.

Step 6: SSA review

SSA typically reviews SSA-44 reconsiderations within 30-60 days. During the review, SSA may:

• Verify the LCE documentation
• Verify the estimated MAGI calculation
• Request additional documentation
• Apply the LCE to the IRMAA determination

Step 7: Initial reconsideration decision

SSA issues a written decision. Outcomes:

• Approval: IRMAA recalculated using estimated MAGI; refunds issued for premiums already paid at the higher rate.
• Partial approval: SSA may approve a different tier than the beneficiary requested if the estimated MAGI doesn't quite reach the standard tier.
• Denial: If denied, the beneficiary can appeal to an Administrative Law Judge.

The Multi-Level IRMAA Appeals Process

Appeal Level 1: Reconsideration (SSA-44 or general)

For LCE-based reconsiderations, the beneficiary uses SSA-44 as described above. For non-LCE-based reconsiderations (e.g., disputed IRS data), the beneficiary requests reconsideration in writing within 60 days of the initial determination.

Appeal Level 2: Administrative Law Judge (ALJ) Hearing

If reconsideration is denied, the beneficiary may request a hearing before an Administrative Law Judge within 60 days of the reconsideration denial. The ALJ hearing is typically conducted by phone or video for Georgia beneficiaries through the Atlanta SSA Office of Hearings Operations (with hearings also held at the Augusta and Savannah offices for those service areas).

At the ALJ hearing:

• The beneficiary or their representative presents evidence
• The beneficiary may testify under oath
• The ALJ may question the beneficiary and any witnesses
• Documents and exhibits are entered into the record
• The ALJ issues a written decision typically within 90 days

ALJ hearings have historically had moderate-to-high approval rates for well-documented IRMAA appeals — particularly LCE-based appeals with strong documentation.

Appeal Level 3: Medicare Appeals Council

If the ALJ denies the appeal, the beneficiary may request review by the Medicare Appeals Council within 60 days of the ALJ decision. The Medicare Appeals Council reviews the ALJ record and either:

• Adopts the ALJ decision
• Modifies the decision
• Reverses the decision
• Remands for further proceedings

Medicare Appeals Council review is typically conducted on the written record without additional hearings.

Appeal Level 4: Federal District Court

If the Medicare Appeals Council denies the appeal, the beneficiary may file a complaint in U.S. District Court within 60 days of the Council decision. For Georgia beneficiaries, this is typically the U.S. District Court for the Northern District of Georgia (Atlanta) or the relevant district court covering the beneficiary's residence.

Federal district court IRMAA appeals are rare because the case is typically resolved at earlier appeal levels, but the option exists for substantial disputes.

Tax Planning Implications

The two-year IRMAA look-back creates tax planning opportunities to manage IRMAA exposure. Key strategies:

Roth conversion timing

A Roth conversion (moving funds from traditional IRA to Roth IRA) is fully taxable as ordinary income in the year of the conversion. A Roth conversion done at age 63 will inflate 2024 MAGI, which determines 2026 IRMAA. Strategy: conduct large Roth conversions BEFORE Medicare eligibility (age 62 and earlier, where possible) to avoid IRMAA impact.

Capital gains realization timing

A large capital gain realized at age 63 inflates 2024 MAGI and triggers 2026 IRMAA. Strategy: realize substantial capital gains BEFORE age 63 to avoid IRMAA impact in the first Medicare year.

Required Minimum Distribution (RMD) planning

RMDs begin at age 73 (under SECURE 2.0 Act of 2022, for those born 1951-1959; age 75 for those born 1960 or later). RMDs are fully taxable as ordinary income and count toward MAGI. Strategy: consider Roth conversions before RMD age to reduce future RMD-driven MAGI.

Qualified Charitable Distribution (QCD)

Beneficiaries age 70½ or older may direct up to $108,000/year (2025 limit, indexed) from a traditional IRA directly to a qualified charity. The QCD satisfies the RMD without counting toward MAGI. Strategy: use QCDs to manage MAGI when charitable giving is part of the financial plan.

Tax-loss harvesting

Realizing capital losses in a tax year can offset capital gains and reduce MAGI. Strategy: in years when MAGI is approaching an IRMAA threshold, harvest losses to stay below the threshold.

Spousal income coordination

For married couples, MAGI is combined. Strategy: time pension distributions, Roth conversions, and other large income events to minimize the combined MAGI in any single year approaching IRMAA thresholds.

IRMAA Coordination with Other Medicare Programs

LIS / Extra Help

The Low-Income Subsidy (LIS) / Extra Help program subsidizes Part D premiums and cost-sharing for low-income beneficiaries. LIS and IRMAA are mutually exclusive — a beneficiary either qualifies for LIS (low income) or for IRMAA (high income), but never both.

For most beneficiaries near the LIS/IRMAA divide, the relevant question is whether they qualify for any LIS level. Asset and income limits for LIS in 2026:

• LIS income limit: approximately $22,590 individual / $30,660 couple (150% of FPL)
• LIS asset limit: approximately $17,220 individual / $34,360 couple

Medicare Savings Programs (MSPs)

The Medicare Savings Programs (QMB, SLMB, QI) help low-income Medicare beneficiaries pay their Part B premiums. MSPs and IRMAA are also typically mutually exclusive at the operational level — MSP recipients have low income, IRMAA payers have high income. Georgia MSP income and asset limits (2026):

• QMB: ~$1,255 individual / ~$1,704 couple monthly income
• SLMB: ~$1,506 individual / ~$2,044 couple monthly income
• QI: ~$1,695 individual / ~$2,300 couple monthly income

Medigap

IRMAA does NOT affect Medigap premiums directly. Medigap premium pricing is based on age, gender, tobacco use, and geographic area — not income. However, beneficiaries paying IRMAA may face higher Medigap rates simply because they are in their first Medicare years (under attained-age rating).

The Georgia IRMAA Context

Affected population

Georgia has approximately 1.5 million Medicare beneficiaries. At the national 7-8% IRMAA rate, that translates to approximately 100,000 to 120,000 Georgia beneficiaries subject to some IRMAA tier each year. The Georgia IRMAA population is concentrated in:

• Fulton County (Atlanta): substantial professional and executive retiree population
• DeKalb County (Decatur, north suburbs): substantial professional and federal retiree population
• Cobb County (Marietta, Smyrna): substantial executive and business owner population
• Gwinnett County: substantial professional and small business retiree population
• Glynn County (Brunswick/St. Simons): substantial high-net-worth retiree population
• Chatham County (Savannah): mixed professional and retiree population
• Forsyth County: rapidly-growing affluent suburban population

Federal retiree concentration

Georgia has substantial federal retiree concentration around:

• CDC (Atlanta): senior researchers, executives, public health officials
• Federal Courts (Atlanta, Augusta, Savannah, Columbus, Macon): judges, magistrate judges, clerks of court
• GSA (Atlanta regional office): federal property management
• DoD Installations: Fort Benning (Columbus), Fort Stewart (Hinesville), Fort Gordon (Augusta), Robins AFB (Warner Robins), Moody AFB (Valdosta) — military retirees with substantial pensions

Federal retirees from these institutions often have peak-earning final-year salaries above $200,000 (single) or $300,000 (joint), triggering Tier 2 or Tier 3 IRMAA in their first Medicare years. SSA-44 work stoppage reconsiderations are common among Georgia federal retirees.

Atlanta SSA Office of Hearings Operations

Georgia IRMAA ALJ hearings are adjudicated through SSA Region IV (Atlanta), with hearings primarily conducted by:

• Atlanta Office of Hearings Operations (downtown Atlanta)
• Augusta Office of Hearings Operations
• Savannah Office of Hearings Operations

Most hearings are conducted by phone or video, with in-person hearings available on request.

GeorgiaCares SHIP

GeorgiaCares SHIP at 1-866-552-4464 provides free IRMAA counseling. Services include:

• Initial IRMAA determination review
• LCE eligibility evaluation
• SSA-44 form completion assistance
• Documentation gathering guidance
• Appeals process navigation
• Tax planning referral to free AARP Foundation Tax-Aide resources

GeorgiaCares does NOT provide tax planning advice (that requires a CPA or tax attorney), but does coordinate with AARP Foundation Tax-Aide (1-888-227-7669) for free tax preparation assistance for moderate-income retirees.

14 IRMAA Best Practices

1. Plan ahead for IRMAA in the years leading up to Medicare. Manage MAGI starting at age 62 to minimize first-year Medicare IRMAA.
2. Time Roth conversions BEFORE Medicare eligibility. Conversions at age 63 inflate 2024 MAGI for 2026 IRMAA.
3. Time large capital gains BEFORE Medicare eligibility. Same two-year look-back rule applies.
4. Read the November IRMAA notice carefully. Don't assume the standard premium will apply.
5. Identify any qualifying LCE. Work stoppage at retirement is the most common.
6. File SSA Form SSA-44 within 60 days of the initial determination.
7. Document the LCE thoroughly. Retirement letters, death certificates, divorce decrees, severance agreements, etc.
8. Provide reasonable basis for estimated MAGI. Calculation worksheets, paystub projections, expected investment income.
9. File in person at a local SSA field office when possible. Immediate question resolution is valuable.
10. Appeal denials promptly. ALJ Hearings have moderate-to-high success rates for well-documented appeals.
11. Coordinate with a tax advisor or CPA. Strategic income timing can save thousands in IRMAA over multiple years.
12. Consider QCDs at age 70½+ to reduce MAGI from RMDs while maintaining charitable giving.
13. Don't confuse IRMAA with LIS or MSPs. IRMAA is for high-income beneficiaries; LIS and MSPs are for low-income beneficiaries.
14. Call GeorgiaCares SHIP at 1-866-552-4464 for free IRMAA counseling.

14 Common IRMAA Issues

1. Surprise IRMAA shock at first Medicare year. Beneficiaries who didn't plan ahead and didn't realize their peak-earning two-year-prior MAGI would trigger IRMAA.
2. Missing the SSA-44 60-day filing window. Late filings face additional barriers.
3. Insufficient LCE documentation. Retirement letters that don't clearly establish the cessation date, or absent severance documentation.
4. Unreasonable estimated MAGI. Estimates that don't align with expected income sources or pension start dates.
5. Confusion about MAGI definition. Beneficiaries assuming Social Security counts (it doesn't, fully) or not including tax-exempt interest (which does count).
6. Roth conversions executed too late. Large conversions at age 63-65 trigger IRMAA two years later.
7. One-time income events. Business sale, inheritance, RMD spike, or large capital gain triggering temporary IRMAA the beneficiary didn't anticipate.
8. Married-filing-separately confusion. MFS thresholds are dramatically lower than married-filing-jointly thresholds.
9. Surviving spouse first-year impact. Death of spouse changes filing status from MFJ to single, often reducing income thresholds disproportionately.
10. Federal retiree work stoppage timing. Retiring late in the year may not generate sufficient MAGI reduction in the same tax year.
11. Not filing tax returns timely. SSA cannot use a more recent return if the beneficiary hasn't filed yet — IRS data is the source.
12. Tax return amendments. Amended returns can update IRMAA calculations, but only after IRS processes the amendment.
13. Multiple LCEs in same year. Combining work stoppage + death of spouse on a single SSA-44 requires careful documentation.
14. **Believing IRMAA is "the same as Medicare." IRMAA is a federal premium surcharge, NOT plan-specific — beneficiaries cannot avoid IRMAA by choosing a different MA or PDP.

Worked Examples

Example 1: Fulton 65 — Atlanta IRMAA shock first Medicare year

Margaret, age 65, retired in December 2024 as a senior partner at an Atlanta law firm. Her 2024 MAGI was approximately $345,000 (final year of partnership distributions). She enrolled in Medicare effective January 2026, expecting standard premiums.

In November 2025, Margaret receives her SSA IRMAA notice: based on 2024 MAGI of $345,000 (single filer), she is in Tier 3 — Part B IRMAA of $295.90/month + Part D IRMAA of $57.00/month = $352.90/month additional premium, or $4,234.80 annual additional cost.

Margaret calls GeorgiaCares SHIP on November 25. The counselor reviews the notice and identifies the work stoppage LCE:

• Margaret retired December 31, 2024
• Her 2026 estimated MAGI is approximately $85,000 (pension + Social Security + investment income)
• $85,000 is below the $106,000 standard threshold

The counselor walks Margaret through Form SSA-44. Margaret obtains a written retirement letter from her firm, a final pay stub, and projects her 2026 MAGI using her pension start date and Social Security benefit notice. She files SSA-44 in person at the Atlanta Downtown SSA field office on December 8.

SSA approves the reconsideration on January 22, 2026. Result:

• Standard Part B premium ($185.00) restored
• Standard Part D premium restored
• Refund of January and February 2026 IRMAA collections issued in March
• Annual IRMAA savings: $4,234.80

Example 2: DeKalb 67 — DeKalb work stoppage LCE reconsideration

James, age 67, retired from his CDC executive role in June 2025. His 2024 MAGI was $215,000 (joint with his wife who has $20,000 part-time income). In November 2025, the SSA IRMAA notice shows joint MAGI of $215,000 places him just into Tier 1 — Part B IRMAA $74.00 + Part D IRMAA $13.70 = $87.70/month additional, or $1,052.40/year.

James calls GeorgiaCares. The counselor explains:

• 2026 estimated joint MAGI (James's federal pension + his wife's continuing $20,000 income + Social Security) = approximately $115,000
• $115,000 is below the $212,000 joint standard threshold

James files SSA-44 in early December at the Decatur SSA office, documenting:

• CDC retirement letter dated June 2025
• Federal pension start notification
• Wife's projected 2026 income
• Social Security benefit notice

SSA approves the reconsideration February 2026. Annual savings: $1,052.40. James also gets two months of refunds.

Example 3: Cobb 68 — Cobb Roth conversion IRMAA spike

Robert, age 68, lives in Marietta. In 2024, he completed a $250,000 Roth conversion on his accountant's advice, expecting to manage IRMAA going forward. His 2024 MAGI was $385,000 (Roth conversion + pension + investment income + Social Security combined with wife's smaller pension).

In November 2025, the IRMAA notice shows joint MAGI $385,000 in Tier 3 — total additional $352.90/month or $4,234.80/year.

Robert calls GeorgiaCares. The counselor identifies:

• No qualifying LCE applies — the Roth conversion was voluntary, not a Life-Changing Event
• 2026 MAGI will return to approximately $145,000 (Tier 1 territory)
• IRMAA will automatically drop in 2027 based on 2025 MAGI

The counselor explains that Robert must pay 2026 IRMAA but should expect Tier 1 IRMAA in 2027 ($87.70/month) and standard premiums in 2028 (assuming MAGI remains under $212,000 joint).

Lesson: Roth conversions trigger IRMAA two years later but auto-correct when MAGI returns to baseline. No LCE applies for voluntary tax planning decisions.

Example 4: Worth County 70 — Worth death of spouse LCE

Linda, age 70, lives in rural Worth County. Her husband died in March 2025. 2024 MAGI was $245,000 (joint, with her husband's substantial pension). In November 2025, the IRMAA notice shows joint MAGI of $245,000 — and because Linda is now filing as a surviving spouse (qualifying widow status for two years), the joint thresholds still apply for 2026. She's in Tier 1 — $87.70/month.

But by 2027 premium year (using 2025 MAGI), Linda will file as single. Her 2025 MAGI is approximately $135,000 (combining her husband's pension survivor benefit + her Social Security + small investment income). Filing as single, the $135,000 puts her into Tier 1 at single thresholds — $87.70/month again, but for a different reason (single $133,001-$167,000 range).

Linda calls GeorgiaCares. The counselor identifies:

• Death of spouse LCE applies for 2026 reconsideration
• Linda's actual 2026 MAGI as single filer (post-survivor benefit transition) is approximately $115,000
• $115,000 single is above the $106,000 standard threshold, putting her in Tier 1 ($87.70/month) regardless

The counselor concludes that an SSA-44 reconsideration would NOT change the IRMAA result — Linda is in Tier 1 either way. The death of spouse LCE doesn't help here because the surviving spouse's MAGI is still above the single Tier 1 threshold.

Lesson: LCE reconsiderations should be filed only when they would actually change the IRMAA tier. Free GeorgiaCares counseling identifies cases where reconsideration won't help.

Example 5: Bibb 66 — Bibb Tier 5 IRMAA former executive

David, age 66, lives in Macon. He sold his manufacturing business in 2024 for a substantial gain, with 2024 MAGI of $1,250,000 (combination of business sale capital gain, accrued salary, and investment income). His wife's separate income is $30,000.

In November 2025, the IRMAA notice shows joint MAGI of $1,250,000 — placing him in Tier 5: Part B IRMAA $443.90/month + Part D IRMAA $85.80/month = $529.70/month additional, or $6,356.40/year.

David calls a CPA and GeorgiaCares. The CPA reviews and confirms:

• The business sale was a one-time event, not a recurring source
• No qualifying LCE applies (sale of business is not on the eight-LCE list)
• 2026 MAGI estimated at $185,000 (joint), but no LCE applies
• 2026 IRMAA will be paid at Tier 5
• 2027 IRMAA (using 2025 MAGI of approximately $185,000 joint) will likely drop to standard premium

David accepts the 2026 IRMAA cost as unavoidable. The CPA helps David plan future income to minimize IRMAA in 2027 and beyond. Lesson: One-time large income events trigger temporary IRMAA but auto-correct over two years. Sale of a business is not an LCE under the SSA-44 framework.

Example 6: Hall 65 — Hall ALJ Hearing appeal after reconsideration denial

Sarah, age 65, lives in Gainesville (Hall County). She retired in October 2024 after 30 years as a Hall County teacher. Her 2024 MAGI was $135,000 (final year of teaching salary + pension start in November + Social Security). In November 2025, the IRMAA notice shows single MAGI $135,000 — Tier 1: $87.70/month additional.

Sarah files SSA-44 in November 2025, documenting:

• Retirement letter from Hall County School District
• Final pay stub from October 2024
• Pension start documentation
• Estimated 2026 MAGI of approximately $85,000

SSA DENIES the reconsideration in January 2026 — finding that Sarah's estimated MAGI is "not sufficiently documented" because her pension start documentation was incomplete.

Sarah calls GeorgiaCares. The counselor recommends an ALJ Hearing appeal. Sarah:

• Files Request for Hearing within 60 days (January 2026)
• Obtains supplemental documentation: detailed pension benefit statement, Social Security benefit notice, investment account year-end statements
• Atlanta Legal Aid (404-377-0701) agrees to represent her

The ALJ Hearing is scheduled for August 2026 (phone hearing). Sarah and her Legal Aid attorney present:

• Complete pension documentation
• Social Security benefit notice
• Investment account statements
• Sarah testifies under oath about her retirement and income expectations

The ALJ GRANTS the appeal in September 2026, finding Sarah's documentation now meets the SSA-44 standard. SSA recalculates 2026 IRMAA:

• Standard Part B premium restored
• Refund of 9 months of IRMAA collections issued in October 2026

Sarah saves the remaining 3 months of 2026 IRMAA plus the 9-month refund — total ~$1,052 for 2026. The appeal process took 10 months but succeeded.

Lesson: Reconsideration denials can be overturned at ALJ Hearing with stronger documentation and legal representation. Atlanta Legal Aid and Georgia Legal Services Program provide free representation for income-qualifying beneficiaries.

Frequently Asked Questions

1. What is IRMAA? The Income-Related Monthly Adjustment Amount — a federal means-tested supplemental premium added to Medicare Part B and Medicare Part D for higher-income beneficiaries.

2. Who pays IRMAA? Medicare beneficiaries whose Modified Adjusted Gross Income (MAGI) from two tax years prior exceeds the standard thresholds — approximately 7-8% of Medicare beneficiaries nationally.

3. What is the 2026 IRMAA threshold for no IRMAA? Single MAGI ≤ $106,000; married filing jointly MAGI ≤ $212,000.

4. What is the highest IRMAA tier in 2026? Tier 5 — Part B IRMAA $443.90/month + Part D IRMAA $85.80/month = $529.70/month additional ($6,356.40/year) — for single MAGI > $500,000 or joint MAGI > $750,000.

5. How is IRMAA MAGI calculated? AGI (Form 1040 Line 11) PLUS tax-exempt interest income (Form 1040 Line 2a).

6. Why does SSA use two-year-prior tax data? Because the IRS doesn't have current-year tax data when SSA sets premiums in November for the following January. The most recently filed and confirmed return is from two years prior.

7. What is SSA Form SSA-44? The "Medicare Income-Related Monthly Adjustment Amount — Life-Changing Event" form, used to request reconsideration when one of eight LCEs has occurred.

8. What are the eight Life-Changing Events? Marriage, divorce/annulment, death of spouse, work stoppage, work reduction, loss of income-producing property, loss or reduction of pension, employer settlement payment.

9. What is the most common LCE? Work stoppage at retirement — recently-retired beneficiaries facing IRMAA based on peak-earning two-year-prior MAGI.

10. How long do I have to file SSA-44? 60 days from the date of the initial IRMAA determination notice.

11. Where do I file SSA-44? At any local SSA field office — Georgia has 27. Filing in person is generally preferred.

12. How long does SSA take to decide? Typically 30-60 days.

13. What if my reconsideration is denied? Appeal to an Administrative Law Judge within 60 days. Atlanta SSA Office of Hearings Operations adjudicates Georgia hearings.

14. What are the multi-level IRMAA appeals? Reconsideration → ALJ Hearing → Medicare Appeals Council → Federal District Court.

15. Does IRMAA apply to Part C (Medicare Advantage)? Indirectly. If your MA plan is MA-PD (includes drug coverage), the Part D IRMAA is added separately to your monthly premium. The Part B IRMAA continues for MA enrollees on top of any plan premium.

16. Does IRMAA apply to standalone Part D PDPs? Yes. Part D IRMAA is collected by SSA regardless of which Part D plan the beneficiary chooses — even a $0-premium PDP.

17. Can I avoid IRMAA by choosing a different Part D plan? No. IRMAA is determined by income, not by plan choice.

18. Does Social Security income count toward IRMAA MAGI? No. Social Security is excluded from IRMAA MAGI definition.

19. Do Roth IRA distributions count toward IRMAA MAGI? No. Qualified Roth distributions are tax-free and do not count.

20. Do Roth conversions count toward IRMAA MAGI? Yes. The converted amount is fully taxable in the year of conversion and counts toward MAGI.

21. Do tax-exempt municipal bond interest payments count? Yes, for IRMAA purposes (unlike for federal income tax purposes).

22. Does IRMAA increase every year? The thresholds are indexed to inflation, but the IRMAA dollar amounts also adjust as Medicare premiums change. Both move with inflation.

23. Can I appeal IRS data SSA used? Yes, if you believe the IRS data is incorrect. The beneficiary must contact the IRS to amend, then SSA can use the amended return.

24. What if I haven't filed a recent tax return? SSA may use older data or estimate. If no tax data is available, SSA may default to certain assumptions. File current returns promptly.

25. Does Georgia have a state-level IRMAA? No. Georgia does not impose any state-level IRMAA-equivalent surcharge.

26. Where can I get free IRMAA help in Georgia? GeorgiaCares SHIP at 1-866-552-4464 — free, unbiased IRMAA counseling for all Georgia Medicare beneficiaries.

27. Can I get free legal representation for an IRMAA ALJ appeal? Yes, if you income-qualify. Atlanta Legal Aid (404-377-0701) covers metro Atlanta; Georgia Legal Services Program (1-800-498-9469) covers the rest of Georgia.

CTA: Free Georgia IRMAA Resources

• Medicare: 1-800-MEDICARE (1-800-633-4227) — federal Medicare information line
• SSA Medicare: 1-800-772-1213 — IRMAA determinations and appeals
• GeorgiaCares SHIP: 1-866-552-4464 — free IRMAA counseling
• Medicare Rights Center: 1-800-333-4114 — national Medicare advocacy
• Center for Medicare Advocacy: 860-456-7790 — IRMAA appeals
• Georgia DCH Member Services: 1-866-211-0950 — Medicaid coverage
• IRS: 1-800-829-1040 — tax return questions
• Atlanta Legal Aid: 404-377-0701 — legal representation for IRMAA appeals
• Georgia Legal Services: 1-800-498-9469 — legal representation outside metro Atlanta
• Eldercare Locator: 1-800-677-1116 — federal eldercare referral service
• 211 Georgia: 211 — local social services referral
• Patient Advocate Foundation: 1-800-532-5274 — chronic disease advocacy
• AARP Foundation Tax-Aide: 1-888-227-7669 — free tax preparation
• Humana Medicare: 1-800-457-4708
• UnitedHealthcare Medicare: 1-800-721-0627
• Aetna Medicare: 1-800-282-5366
• Anthem Medicare: 1-833-919-1577
• Wellcare Medicare: 1-833-444-9088

Last verified: 2026-05-14. IRMAA thresholds and surcharges change annually. Always verify current values at medicare.gov or by calling GeorgiaCares SHIP at 1-866-552-4464. Tax planning decisions should involve a qualified CPA or tax attorney. This guide is informational and does not constitute legal, financial, or tax advice.