The government sure gets creative when it needs more revenue.
And guess where that additional revenue often comes from? That’s right: higher earners and good savers… like our clients.
For years, the Medicare program has been in dire need of additional funds. Congress attempted to address this need in 2003, when, as part of the Medicare Modernization Act, they created IRMAA.
For the uninitiated, IRMAA, or the Income-Related Monthly Adjustment Amount, is an additional surcharge placed on Medicare Part B and Part D for certain higher-earning Americans.
The idea behind IRMAA? An easy way to support the financial solvency of Medicare is by having higher-income Americans pay more for their Medicare coverage.
So how has IRMAA impacted savers – and why should you be talking to your clients about it?
Why IRMAA Matters
I believe IRMAA is important to your clients for two reasons – one practical and one philosophical:
Practical: Many of our clients will be subject to IRMAA once they elect their Medicare coverage. IRMAA surcharges start with about $218,000 of income (MAGI) for couples and $109,000 of income (MAGI) for individual filers. Our clients may have income needs that immediately subject them to IRMAA, or our clients may avoid IRMAA while filing jointly, but become subject to IRMAA once one spouse passes away and the surviving spouse is subject to a lower income threshold.
Philosophical: IRMAA has been a tremendous triumph for the Medicare program. This “stealth” new fee is raising significant revenue and keeping the Medicare Part B and D trust funds solvent. IRMAA represents, in my opinion, a new wave of government revenue generation. Through it, Congress has found a way to get more funding for government programs without changing tax bracket rates. I believe we’ll see more income-related fees and taxes created in IRMAA’s image going forward.
So where are IRMAA rates headed – and how should our clients prepare?
A Little Historical Perspective
IRMAA rates have risen pretty steadily since the program’s inception.
This isn’t surprising – once the government finds a new revenue source, they want to maximize the revenue it generates. The Medicare program continues to need more money, so the government continues to increase IRMAA fees.
(Fun fact – or not so fun if you’re paying IRMAA. Congress doesn’t even need to vote for your client’s IRMAA rates to rise. In fact, the Centers for Medicare & Medicaid Services (CMS) just adjusts the IRMAA brackets and rates each year, based on the percentage movement of the Consumer Price Index and the experience and needs of the Medicare program.)
I wish I had a magic ball to see what IRMAA rates will be in the future for our clients. But lacking that kind of magic, instead I’ve been looking at historical IRMAA trends to see what insights they might provide.
There are two trends that are apparent in the data. (For simplicity’s sake, I’ll base all these numbers off the first tier of IRMAA surcharges.)
IRMAA surcharges first went into effect in 2007. And for the first few years of the program, those rates ramped up significantly as the government got a handle on the new revenue and how to set rates to match program needs.
I like to look at 2012 as the program’s first stabilized year. Since 2012, we’ve seen many years where increases were implemented (some significantly – more on that in a moment). We’ve also seen a few years (like 2012 and 2023) where IRMAA rates were flat or actually decreased.
Overall, for the first IRMAA tier, rates have increased by about 4.6% annually since 2012. So over time, we’re seeing this compounding program cost steadily rise.
Those rate increases have been coming more aggressively in recent years. Since 2019, IRMAA fees in the first tier have risen around 7.3% a year. And over the last three years, they’ve risen steadily, too: 6% (2024), 5.9% (2025) and a whopping 9.1% (2026).
What Lies Ahead
Unfortunately for our clients, there’s a good chance the historical trends will continue and IRMAA surcharges will keep on rising.
We know the Medicare program will require significantly more funding in the years ahead. The Centers for Medicare and Medicaid Services (CMS) projects that through 2033, the government’s Medicare spending will grow at more than 7% annually. The government will need additional revenue to meet this growth in outlays.
In fact, the government has already warned U.S. savers that premiums and surcharges over the next decade will amount to approximately 25% of a saver’s overall Social Security benefit.
So it’s very reasonable to project an increasing impact from IRMAA on our clients.
How to Help Our Clients Prepare
That’s a lot of data points for you to consider. So what does it all mean for our clients?
First, we have to educate clients about IRMAA and its potential impact on their retirement income.
This discussion becomes particularly important as savers consider Roth conversions. The reason is twofold:
First, over time, a Roth conversion can help a saver lower their MAGI and, therefore, their IRMAA surcharges. For the purposes of IRMAA, the SSA calculates a saver’s MAGI based on taxable income from 401(k)s, IRAs, working income, and the taxable portion of their Social Security benefit. However, income from Roth accounts do not count toward MAGI for the IRMAA calculation. By accessing retirement funds from a Roth account in the future, your client can potentially lower or eliminate their IRMAA surcharges.
Second, IRMAA is an important consideration as you structure a client’s Roth conversion. As we know, clients often like to spread out a Roth conversion over a number of years to avoid an inflated tax bill in a given year. So advisors need to analyze not only tax drift (or the potential for pushing a saver into a higher tax bracket during the conversion) but also IRMAA drift (analyzing if the additional income from the conversion pushes the saver into a higher IRMAA bracket during those conversion years).
At Stonewood Financial, we feel so passionately about helping savers minimize both taxes and IRMAA in retirement that we created our Roth Done Right software to analyze these scenarios for your clients. If you haven’t checked it out, we’re happy to send you a sample report for one of your clients so you can see how powerful the IRMAA analysis can be.
IRMAA will continue to be a hot topic as Congress debates how to stabilize the Medicare program. Smart advisors will help their clients get ahead of the debate.
The Complete 2026 IRMAA Brackets
The historical trend above tells you where IRMAA has been. Here’s exactly where it stands right now. The 2026 IRMAA brackets have five tiers above the standard premium, based on a saver’s 2024 MAGI, the income figure Medicare uses under its two-year lookback.
2026 IRMAA Brackets for Single Filers
2024 MAGI (Single)
Total Part B Premium
Part D Surcharge
Multiplier
$109,000 or less
$202.90
$0.00
1.0x
$109,001 to $137,000
$284.10
$14.50
1.4x
$137,001 to $171,000
$405.80
$37.50
2.0x
$171,001 to $205,000
$527.50
$60.40
2.6x
$205,001 to $499,999
$649.20
$83.30
3.2x
$500,000 or more
$689.90
$91.00
3.4x
2026 IRMAA Brackets for Married Filing Jointly
2024 MAGI (Joint)
Total Part B Premium
Part D Surcharge
Multiplier
$218,000 or less
$202.90
$0.00
1.0x
$218,001 to $274,000
$284.10
$14.50
1.4x
$274,001 to $342,000
$405.80
$37.50
2.0x
$342,001 to $410,000
$527.50
$60.40
2.6x
$410,001 to $749,999
$649.20
$83.30
3.2x
$750,000 or more
$689.90
$91.00
3.4x
Each amount is per person, per month, so a married couple who are both on Medicare and both land in the same tier each pay the full surcharge shown above. IRMAA also works as a cliff rather than a gradual slide. A single dollar of MAGI over a threshold triggers the entire next tier’s surcharge, not a prorated amount, which is exactly the kind of edge a multi-year Roth conversion plan needs to account for.
The first four tiers are indexed for inflation each year. The top tier, added by the Bipartisan Budget Act of 2018, is currently frozen and isn’t scheduled to be indexed again until 2028.
Total Annual IRMAA Cost per Couple by Tier
For clients who file jointly and are both on Medicare, the per-couple IRMAA cost per year lands like this. This is often the most useful table for pricing the annual IRMAA drag of a conversion year.
Tier
Joint MAGI Range (2024)
Annual IRMAA Cost per Couple
No IRMAA
$218,000 or less
$0
Tier 1
$218,001 to $274,000
$2,297
Tier 2
$274,001 to $342,000
$5,770
Tier 3
$342,001 to $410,000
$9,240
Tier 4
$410,001 to $749,999
$12,710
Tier 5
$750,000 or more
$13,872
Figures reflect twelve months of the IRMAA surcharge amounts on each spouse, computed from the CMS 2026 fact sheet linked in the Sources and References section below.
What Counts, and Doesn’t Count, Toward IRMAA MAGI
IRMAA MAGI is a specific creature. It’s your client’s adjusted gross income from Form 1040, line 11, plus any tax-exempt interest from line 2a. That last line is what surprises people. Municipal bond interest, held for years because it’s “tax-free,” counts fully toward IRMAA.
Counts Toward IRMAA MAGI
Traditional IRA and 401(k) distributions, including RMDs
Roth conversions (in the conversion year)
The taxable portion of Social Security benefits
Wages, self-employment income, and pension income
Capital gains, including mutual fund distributions
Rental income
Tax-exempt interest, including municipal bond interest
Doesn’t Count Toward IRMAA MAGI
Qualified withdrawals from a Roth IRA or Roth 401(k)
HSA distributions used for qualified medical expenses
Life insurance death benefits received by a beneficiary
Loan proceeds, including reverse mortgage advances
Return of basis on non-qualified account withdrawals (only the gain portion counts)
This is where asset location and product mix quietly does a lot of work over a retirement. Every dollar in a Roth, an HSA, or a cash-value life insurance policy is a dollar that can be accessed later without moving IRMAA. Annuity Alpha is one of the tools we use to compare that trade-off in a non-qualified income structure.
The QCD Lever for Clients Already Taking RMDs
A Qualified Charitable Distribution lets a client 70 1/2 or older send funds directly from an IRA to a qualified charity. The distribution counts toward the RMD but doesn’t add to AGI, and therefore doesn’t add to IRMAA MAGI. For charitably-inclined clients whose RMDs are pushing them into a higher IRMAA tier, sizing part of the RMD as a QCD can be the difference between crossing a bracket and staying under it.
The Widow’s IRMAA Trap
As I mentioned above, couples who avoid IRMAA together can hit it hard once one person passes and the surviving spouse is hit with the single-filer IRMAA rates. It’s worth walking through the mechanics, because this is often the single most valuable IRMAA conversation an advisor can have with a couple in their sixties.
When one spouse dies, the surviving spouse files as Single starting the year after the death. IRMAA brackets for Single filers are roughly half the joint thresholds through the first four tiers. Meanwhile, household income often doesn’t drop by half. One Social Security check goes away, but pensions, IRA distributions, RMDs, and other income often keeps flowing at the same level.
When a Client Gets an IRMAA Notice They Didn’t Expect: The SSA-44 Appeal
This is often the fastest win an advisor can deliver to a new Medicare-eligible client, and it’s missing from most of the IRMAA articles out there.
If a client’s 2024 income was inflated by an event that no longer reflects current income, they can file Form SSA-44, Request to Lower an Income-Related Monthly Adjustment Amount, and ask Social Security to use a more recent year. The client has 60 days from the date of the IRMAA notice to appeal.
Qualifying Life-Changing Events
Marriage
Divorce or annulment
Death of a spouse
Work stoppage
Work reduction
Loss of income-producing property
Loss of pension income
Employer settlement payment
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The Most Common Advisor Win
A client who retired in 2025 has a 2024 tax return with a full year of employment income. Social Security uses that 2024 return to price their 2026 Medicare premium, and the client gets an IRMAA notice they weren’t expecting. Filing SSA-44 with 2025 income documentation asks Social Security to swap in the more recent, lower-income year. Approvals for legitimate work-stoppage events are common.
Advisors we work with often flag SSA-44 in the first meeting with any new Medicare-eligible client whose IRMAA notice looks off. It’s a genuinely helpful win that costs the client nothing.
OBBBA and IRMAA: The Urgency Isn’t Off
Some talking heads have suggested the Roth conversion urgency is off, because today’s lower tax-bracket rates were legislatively extended. I reject that idea, and IRMAA is one of the reasons.
“Permanent” in the OBBBA context only means today’s tax bracket rates won’t automatically go up – they’ll only rise if and when Congress votes to raise them. Given the trajectory of federal spending and the Medicare program’s own funding needs, I still expect rates to move back toward pre-TCJA levels within the decade. In the meantime, IRMAA continues to rise on its own, without a Congressional vote, because CMS adjusts the surcharges every year based on the experience of the Medicare program.
OBBBA also shifts the income landscape underneath IRMAA. Bracket structure, the new senior standard deduction, SALT cap changes for high-tax-state clients, and QBI phase-in thresholds all move taxable income at the same gross income. Every Medicare-eligible client’s IRMAA exposure is worth reprojecting under the 2026 parameters, not the 2025 ones.
Frequently Asked Questions
What is IRMAA for 2026?
IRMAA, the Income-Related Monthly Adjustment Amount, is a surcharge Medicare adds to Part B and Part D premiums for higher-earning beneficiaries. For 2026, it applies once a saver’s MAGI, based on their 2024 tax return, exceeds $109,000 for single filers or $218,000 for joint filers.
What are the IRMAA brackets for 2026?
The 2026 IRMAA brackets have five tiers above the standard Part B premium of $202.90. Total monthly Part B premiums range from $284.10 at the first tier to $689.90 at the top tier (MAGI of $500,000 single or $750,000 joint), with Part D surcharges adding $14.50 to $91.00 on top of a saver’s plan premium. The full table is above.
What income counts toward IRMAA?
IRMAA uses modified adjusted gross income (MAGI): adjusted gross income from 401(k)s, IRAs, working income, and the taxable portion of Social Security, plus any tax-exempt interest. Qualified withdrawals from Roth accounts do not count toward MAGI for IRMAA purposes.
Why does IRMAA use a two-year lookback?
Medicare uses the most recent tax return the IRS has on file when premiums are set for the coming year, which is generally two years prior. That means 2026 IRMAA is based on 2024 MAGI, so a Roth conversion or other income event in 2026 won’t affect Medicare premiums until 2028.
Can a Roth conversion trigger IRMAA?
Yes, in the short term. A Roth conversion raises MAGI in the year it happens, which can push a saver into a higher IRMAA tier two years later. Over the long term, though, money that has been converted to a Roth no longer counts toward MAGI when withdrawn, which can reduce or eliminate IRMAA exposure in later years. Advisors need to weigh both effects together, not just the immediate one.
How do I appeal an IRMAA surcharge?
File Form SSA-44 with Social Security within 60 days of the IRMAA notice, documenting a qualifying life-changing event: marriage, divorce, death of a spouse, work stoppage or reduction, loss of income-producing property, loss of pension income, or an employer settlement payment. Approval asks Social Security to use a more recent year of income.
What is the IRMAA widow trap?
When a spouse dies, the surviving spouse files as Single, where IRMAA brackets are roughly half the joint thresholds. Household income often doesn’t fall proportionally, so the surviving spouse can jump one or two IRMAA tiers with no real change in income. Roth conversions while both spouses are alive are one of the strongest defenses.
Did OBBBA remove the urgency on Roth conversions?
No. OBBBA legislatively extended lower rates, but “permanent” only means Congress must vote to change them. Given federal spending trajectories and Medicare funding needs, I still expect rates to move toward pre-TCJA levels within the decade. IRMAA also continues to rise on its own without any Congressional vote.
How does Roth Done Right help with IRMAA planning?
Stonewood’s Roth Done Right software models a multi-year Roth conversion scenario using current and assumed tax and IRMAA rates. The output is a client-facing report built for you to walk through with the client to evaluate taxes and IRMAA paid vs. taxes and IRMAA saved in an optimized structure.
Is Stonewood an IMO?
No. Stonewood provides software, client reports and marketing tools to independent financial advisors. Our tools work with any carrier through any IMO.
Two-year MAGI lookback, SSA-44 appeal process, 60-day appeal window, and qualifying life-changing events are from: Social Security Administration, Form SSA-44 (12-2025), “Medicare Income-Related Monthly Adjustment Amount, Life-Changing Event.” Available online: https://www.ssa.gov/forms/ssa-44.pdf
MAGI definition (AGI plus tax-exempt interest for IRMAA purposes) is from: Social Security Administration, “Medicare Premiums: Rules for Higher-Income Beneficiaries.” Available online: https://www.ssa.gov/benefits/medicare/medicare-premiums.html
Top-tier bracket freeze through 2028 is from: the Bipartisan Budget Act of 2018, as reflected in the CMS 2026 fact sheet cited above.
Becky helps your clients outsmart Washington and take control of their retirement. Making the complex simple and meaningful? It’s all in a day's work.
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