IRMAA Appeals

Understanding the IRMAA Determination Notice and Response Process

Verified against SSA POMS as of August 17, 2026

IRMAA Determination Notice and Appeal Rights

The Social Security Administration (SSA) uses data from the Internal Revenue Service (IRS) to initially determine a beneficiary's Income-Related Monthly Adjustment Amount (IRMAA). Once an IRMAA determination is made, SSA informs the beneficiary through a notice that includes the determination and outlines the beneficiary's right to appeal. Beneficiaries have 60 days from the receipt of this notice to file a request for reconsideration of the IRMAA determination notice. The date of receipt is considered to be 5 days after the date on the notice unless proven otherwise. 

IRMAA Determination and Reconsideration Notices

IRMAA notices provide beneficiaries with information about SSA’s determination based on their modified adjusted gross income (MAGI). Notices for Medicare Part B and Part D enrollees include information about the higher premium and how it was determined. The notice also provides details about how beneficiaries can appeal the determination or request a new initial determination. Predetermination notices, however, do not include appeal rights and only indicate planned actions. Additionally, there are Reconsideration notices, which can either dismiss, affirm, or reverse an earlier determination by the SSA that was challenged by the beneficiary. 

Levels of IRMAA Appeals

There are four levels of IRMAA appeals: 1) Reconsideration processed by the SSA field office, 2) Hearing before a Department of Health and Human Services (DHHS) Administrative Law Judge (ALJ) in the Office of Medicare Hearings and Appeals (OMHA), 3) Review by the DHHS Medicare Appeals Council (MAC), and 4) Federal Court Action. If a beneficiary disagrees with the IRMAA determination, they may not always need to appeal, as a new initial determination could resolve their issue without the need for an appeal. 

Request for New Initial Determination

Beneficiaries can request a new initial determination if they have a qualifying circumstance, such as a change in MAGI due to life events, or more recent/corrected tax data. This request should be filed within the appeals period, or later only if good cause is shown. New initial determinations use beneficiary-provided data rather than IRS data if the qualifying circumstances are proven. 

Annual Verification Notices

Annual verification notices involve an examination of IRS data to verify IRMAA levels. A predetermination notice is sent if there is a plan to adjust IRMAA based on the verification. Beneficiaries may respond with corrected data to prevent changes before implementation. Correction notices following annual verifications include rights to appeal. 

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