IRMAA Appeal: Life-Changing Events and Form SSA-44

The regulation, 20 CFR 418.1205, lists seven major life-changing events, because it counts stopping work and reducing hours as one. Form SSA-44 and SSA’s manual split that item, so the form has eight boxes. The table gives the regulation’s wording and the evidence SSA says it needs, from page 8 of the form. SSA’s manual calls the list exclusive:

SSA also needs proof of your income for the year you ask it to use. The regulation says what it prefers, and what it accepts when you have not filed that year’s return:

For work, the regulation says:

For loss of property, the regulation adds what counts:

The form adds what proof of fraud or theft needs:

Two differences between the columns are worth knowing. For divorce, the form’s box applies when you will not file a joint return with your spouse for the year. For the settlement box, the form names bankruptcy or reorganization where the regulation says closure, bankruptcy, or reorganization.

The regulation also says the event must produce a reduction that matters. It counts only a reduction that lowers your IRMAA tier or removes IRMAA:

Filing status adds a wrinkle. The regulation counts a reduction as significant only if MAGI decreases and the decrease changes your IRMAA:

But Form SSA-44’s instructions say:

So if marriage, divorce or a spouse’s death changes your filing status and your premium would be lower even though your MAGI is not, the calculator shows a neutral “possible” result instead of a qualifying one. SSA decides. The calculator compares dollars, not tier numbers, because married filing separately (lived with spouse) has its own three-tier table.

Both spouses can be affected. SSA’s manual says a report applies only to the person reporting:

If you and your spouse both pay IRMAA and the event affects both of you, each of you needs to contact SSA.

The regulation says the list is closed, and gives two examples of what is not an event:

• “Events that affect your expenses, but not your income”
• “Events that result in the loss of dividend income because of the ordinary risk of investment.”

SSA’s manual gives more examples of events and income reductions that are not life-changing events:

• “Ordinary loss of dividend income”
• “Higher medical expenses”
• “Higher living expenses”
• “Loss of child support”
• “Loss of alimony”
• “Voluntary sale of income-producing property.”

The same manual says that if a one-time event raised your income in the year SSA used, such as a conversion of an IRA (a Roth conversion is one), it is also a non-qualifying event. Its examples of one-time income:

• “Capital gains from the sale of property”
• “Lottery winnings”
• “Casino winnings”
• “Conversion of an IRA”
• “Cashing bonds.”

The manual notes one exception: loss of dividend income because of criminal theft could qualify as loss of income-producing property (HI 01120.035). If you file anyway, SSA’s manual has it review what you send and explain that the event does not qualify. If you still insist on a decision, SSA processes a dismissal. The regulation says SSA dismisses a request for a new initial determination that does not fit one of its listed circumstances, and that the dismissal itself cannot be appealed:

What you can appeal is the original IRMAA determination, by requesting reconsideration within 60 days of receiving its notice (SSA’s manual, HI 01140.001 B). A dismissal can help you if you are then late:

That is why the calculator above shows “none of these” as not eligible for Form SSA-44.

The regulation sets the normal rule, the two-year lookback:

For 2026 premiums, SSA says this is usually tax year 2024:

When IRS cannot supply that year, SSA falls back one more year:

And it can use a newer year when you ask and meet the event rules:

Form SSA-44 tells you which newer year to choose. For a 2026 request, use 2026 if your income is lower in 2026 than in 2025 (for example, you stopped working in 2026, or your income fell in 2025 and falls further in 2026). Use 2025 if your income was cut in 2025 and is not lower in 2026. If SSA used 2023 because IRS had no 2024 data, you may ask SSA to use 2024. Two rules on the form:

You can send an estimate if you have not filed the return for that year. The form says:

That is why the calculator asks for your estimated MAGI for the more recent year, not your 2024 return. MAGI is adjusted gross income plus tax-exempt interest, so include tax-exempt interest, even though it is not in AGI.

SSA’s “Request to lower an IRMAA” page describes the request this way:

Form SSA-44 is not required, but it is the form SSA provides for this request. The form itself says so:

1. Check that you pay IRMAA. Look at your SSA notice for the tax year SSA used and your tier. Do not use the form if you do not pay IRMAA:

   “If you do not have to pay an income-related monthly adjustment amount, you should not fill out this form even if you experienced a life-changing event.”

2. Pick the event and the tax year. Tick the box or boxes on Step 1 and give the month and year of the event. Step 2 is the actual or estimated adjusted gross income and tax-exempt interest and your filing status for the more recent year. Step 3 is optional: an estimate for the year after, if your income will be lower again. If you skip it, SSA’s manual says:

   “If they give an estimate for the current premium year, but not for the next premium year, use the current year estimate for the next premium year.”

3. Gather the evidence in the table above, plus your signed tax return or IRS transcript for the year you ask SSA to use, if you have filed it. If you have not filed it, SSA accepts an estimate and will ask for a signed copy of the return when you file. Use the checklist in the calculator for your event.
4. Sign and send it. You sign under penalty of perjury in Step 5. You can mail or fax it. SSA’s page says:

   “Fax or mail your completed form and evidence to a Social Security office.”

   SSA’s page also has an online route that asks you to sign in to fill out and submit the form, and a way to make an appointment. The form lists a phone number, 1-800-772-1213 (TTY 1-800-325-0778), for calling to ask for an appointment at a local Social Security office. The sources do not give one mailing address, so use the office SSA points you to. SSA says it will mail your original documents or certified copies back to you, or you can show them to an SSA employee.

5. What happens next. The form says SSA will check your statements with IRS records. SSA’s manual says SSA does not question what makes up your MAGI when you state the event caused the reduction; it checks that MAGI went down and that the event came first:

   “If the beneficiary attests under penalty of perjury that the LCE caused the significant reduction in income, we accept that statement.”

   SSA then makes a new initial determination. If it lowers your IRMAA, the new tier applies from the effective date below. The sources do not state how long SSA takes.

When the new decision takes effect

The regulation’s main rule is in 20 CFR 418.1230(a). Its paragraphs (b) and (c) cover two other situations, below.

Two other situations apply. If the event falls late in the year, you have until March 31, and SSA’s decision can reach back to January 1 of the year of the event (20 CFR 418.1230(b)):

If your income will not drop until the next year, the decision is for that year:

When you can ask:

Form SSA-44 is for income that went down because of a life-changing event. A reconsideration (Form SSA-561-U2) is an appeal of SSA’s decision. SSA says you often do not need to appeal:

Wrong IRS data goes through a new initial determination, not an appeal. SSA’s page says:

And the regulation, for a reconsideration filed only for that reason:

SSA’s manual for the correction route:

IRS will provide the documentation of the error:

SSA accepts a correction even when it goes against you, so check what IRS is correcting first:

If you filed an amended return

SSA can use the amended return for the same tax year it used. The regulation sets a time limit and the proof SSA needs:

The POMS says SSA will accept an amended return as a correction to MAGI or as evidence of MAGI in conjunction with a life-changing event, and:

One limit from the same manual page:

SSA’s page tells you how to start:

SSA’s manual also says it can use an amended return even if the new figures raise IRMAA, so an amended return is not only a way to lower it. If the amended return is the only reason your income changed, use the amended-return route; a life-changing event is not needed.

If SSA used outdated data

If IRS gave SSA only the older tax year (tax year 2023 for a 2026 premium) and you have filed the newer one, you can give SSA a copy of your filed return. The regulation lets you ask for a new initial determination from the date you get SSA’s notice until the end of the premium year. If you get the notice in the last 3 months of a calendar year, you have until March 31 of the following year.

One more case: you filed married filing separately but lived apart from your spouse all year. The form says:

When reconsideration is the right form

Reconsideration fits when you disagree with SSA’s decision itself, for example you think SSA applied the wrong IRMAA level to the income IRS reported. SSA’s manual gives the timing and the receipt rule:

A reconsideration request can be filed within 60 days of receiving the IRMAA notice, and late requests are reviewed for good cause. SSA’s page names the form:

The manual adds that a new initial determination often gives the same result, and that you can do both at once:

The form you sign says SSA will check what you tell it with IRS:

If IRS reports different income, SSA corrects the months it already decided:

In plain words, the “except when paragraph (c) applies” at the end covers one case. If SSA already used your amended return, or your IRS proof that its data was wrong, it will not adjust again based on later IRS data for those years:

The form tells you to update SSA yourself, and warns what happens if you do not:

You can revise the estimate as often as needed, but not to a worse result than IRS data would give:

The regulation says SSA accepts new MAGI information at any time after your request until the end of the calendar year after the more recent tax year it used. If you amend your return for that year, the amended-return rules above apply. The form says SSA keeps using your Step 2 estimate for the following year until IRS sends the return information for that year, you provide a signed copy of your filed or amended return with a different amount, or you provide an updated estimate.

In practice that means a wrong estimate is not final in either direction. The form says corrections can include retroactive assessments or refunds, so keep your premium notices and your filed return.

All three examples use the official 2026 CMS amounts (the same ones on the 2026 IRMAA brackets page) and the calculator’s arithmetic. As of October 28, 2026, 2027 IRMAA amounts have not been announced, so the page does not run examples for 2027. Our 2027 IRMAA brackets page covers the thresholds, and the 2028 estimate is a scenario, not an official number.

Annual figures assume IRMAA for 12 months. Your amount differs if you enrolled in Part B or Part D partway through the year.

IRMAA calculator for your 2026 premium by income; IRMAA brackets 2026 for the official tiers; IRMAA brackets 2027 and IRMAA brackets 2028 to see which income year each premium year uses; Medicare Part B premium 2027 for the standard premium.