IRMAA Brackets and QLACs

A reader wonders whether their lower 2024 income will automatically reduce their 2026 IRMAA surcharge (even though it doesn’t qualify for an SSA-44) or whether they must contact the Social Security Administration.

“My 2024 income decreased, not for any of the reasons listed on the SSA-44 form. I simply didn’t do Roth conversions in 2024. Will the Social Security Administration automatically reduce my 2026 IRMAA surcharges, or do I need to contact them? My 2024 MAGI qualifies me for the next-lower IRMAA bracket than it did in 2023.”

You won’t have to notify Social Security because, by default, they use your actual reported Modified Adjusted Gross Income (MAGI) from your 2024 income tax return for your 2026 IRMAA calculation. That year’s AGI will be lower because, in your words, you reduced the Roth conversions you made in 2024 compared to the prior year, 2023.

For the 2026 IRMAA, they will automatically review your 2024 income tax return. So, when you are seeking an adjustment based on such a reduction, there’s no need to contact them.

It’s only if you had both a life-changing event (as defined by Social Security’s Form SSA-44) and if your current income was even lower that you could ask them, “Hey, don’t look at 2024. Please use my 2026 anticipated income instead to determine my 2026 IRMAA.”

However, it doesn’t sound like you’re requesting that. You’re simply noting that your 2024 adjusted income would move you into a lower IRMAA premium bracket. Your question is, “Do I need to do anything?” and the answer is simply no.

People are already receiving their Medicare premium letters for next year, which are arriving now in late November. I haven’t seen one yet, but at least one person has told me the letter has arrived. In any case, they’re being issued as I write this. If you haven’t received yours, it should arrive shortly.

As a side note, if you’re planning to file an SSA-44 for your 2026 IRMAA, you need to wait until the 2026 form is released. It’s not out yet. (Social Security simply replaces the existing form online with a new one.) If you go to SSA.gov today, under Forms, the SSA-44 form at the very top indicates it was released in December 2024, a full year ago. It will be replaced again this December, when they release the 2026 IRMAA.

A lot of people like to jump the gun and try to get that form as early as possible. You need to wait until your Medicare premium determination letter arrives, showing that you’re being charged an IRMAA premium. At that point, you have something to appeal if you have a life-changing event, as defined on Form SSA-44, and your income is actually lower. You can then ask to use the current year’s income rather than income from two years ago.

Because you need to wait for that form to be released, you’ll likely pay IRMAA for a couple of months in the upcoming year, maybe January and February, but they will make you whole. Social Security will credit you if they determine they should not have charged you that level of IRMAA, if any.

I wish they would change the timing of this process because it’s frustrating for many people. They don’t get access to the form early enough to appeal. They can’t file it until they’re actually assessed, and by then they’ll already be automatically charged the incorrect January IRMAA designated by Social Security – even though Social Security might agree that they qualify for relief.

The situation will eventually be resolved. You might pay IRMAA for a month or two, but there’s no way to avoid it.

Although this isn’t something that affects you this year, I wanted to mention it as we’re approaching the season when people file their SSA-44.