Can Medicare IRMAA be appealed or reduced if Roth conversions spike MAGI temporarily?
Executive summary
A Roth conversion that temporarily spikes Modified Adjusted Gross Income (MAGI) can and often does trigger IRMAA because Medicare uses a two‑year lookback and counts conversions as taxable income (so a 2024 conversion can affect 2026 premiums) [1] [2]. Beneficiaries can request a redetermination from Social Security using Form SSA‑44 if their income has changed due to qualifying circumstances, but routine one‑time conversions are not a guaranteed basis for relief and many advisers warn appeals "are not granted just because you did a Roth conversion" [3] [4].
1. Why a Roth conversion can bite you for two years
Medicare’s IRMAA surcharge is calculated from MAGI two years prior to the premium year, so a large Roth conversion in year X increases that year’s MAGI and can push a beneficiary over an IRMAA cliff for year X+2; the system is binary at thresholds — even $1 over can trigger substantially higher Part B and Part D surcharges [2] [1] [5].
2. The formal appeal route — SSA‑44 and redetermination
Social Security allows beneficiaries to seek a redetermination if income has fallen or changed because of a life‑changing event; the process uses Form SSA‑44 (Medicare Income‑Related Monthly Adjustment Amount – Life‑Changing Event) and has time limits and documentation requirements that applicants must meet [6] [3] [7].
3. What counts as an acceptable reason to lower IRMAA
Published guidance and reporting repeatedly stress that qualifying reasons typically involve substantive, sustained changes — retirement, death of a spouse, loss of pension, work stoppage or similar life‑changing events — rather than routine one‑time transactions; several outlets explicitly say appeals are granted when income has genuinely dropped due to these events, but not merely because a single transaction increased MAGI two years earlier [2] [4] [3].
4. The gray area: one‑time spikes, conversions and how SSA treats them
Practitioner guidance acknowledges that one‑time events (big Roth conversions, capital gains, severance) can “spike MAGI and trigger IRMAA for a full year two years later,” and some sources advise filing appeals where income subsequently fell — but they also caution that a one‑time taxable event by itself is often not sufficient to win a redetermination unless tied to a qualifying life change or demonstrable, continuing reduction in income [2] [8] [4].
5. Practical implications and planning tradeoffs
Financial planners urge proactive timing: spreading conversions, completing Roth conversions well before Medicare lookback years, or accepting a single year of IRMAA in exchange for longer‑term benefits (no RMDs, tax‑free growth) are common strategies; Roth distributions do not count toward MAGI, and conversions can reduce future RMD‑driven MAGI, but the immediate consequence can be a costly one‑year IRMAA spike [9] [10] [11].
6. Bottom line: appeal is possible but not automatic; plan accordingly
Yes — there is an appeal mechanism (Form SSA‑44) and relief is available when income truly changed due to qualifying life events or sustained decline, but a temporary MAGI spike from a Roth conversion is not an automatic ticket to reversal and many advisers warn appeals “are not granted just because you did a Roth conversion”; therefore the effective answer is conditional: appeal if circumstances fit SSA criteria, but better financial planning (timing/spreading conversions) is the more reliable way to avoid unintended IRMAA consequences [3] [4] [9].