Medicare is charging you based on income you no longer have. One form can fix that.

Written by Henry Supinski, MBA, ChFC®, founder of Blackshire Wealth Management · Last reviewed August 2026

Why your premium is based on the wrong year

Medicare sets IRMAA surcharges using your Modified Adjusted Gross Income from two years prior, because that is the most recent tax return the IRS has fully processed when premiums are set. For someone with steady income, the lag is invisible. For someone who just retired, it is expensive: your first Medicare premiums get priced off your final working years, which for many people include a severance payout, a vacation payout, and a last stretch of full salary stacked into one return.

The Social Security Administration knows this, which is why the appeal process exists. It is not a special exception you have to argue for. It is a standard form with a standard set of qualifying events. You just have to file it, correctly.

The eight qualifying life-changing events

SSA-44 only applies if your income dropped because of one of these events:

• Work stoppage. You retired or otherwise stopped working. This is the most common reason, and it covers voluntary retirement, taking an early retirement package, and being laid off.
• Work reduction. You cut back hours or moved to part-time, and your income fell.
• Marriage.
• Divorce or annulment.
• Death of a spouse.
• Loss of income-producing property due to circumstances beyond your control, such as a disaster or theft, not an ordinary sale.
• Loss of pension income because a plan was terminated or reorganized, not because you spent it down.
• Employer settlement payment received because of an employer's bankruptcy or reorganization.

Notice what is not on the list. A large Roth conversion, a big capital gain, selling a house, a spike from RMDs: none of these qualify, even though they raise your premiums two years later. If the high income was real and no qualifying event caused a drop, there is no appeal. That is exactly why income events near Medicare age should be planned against the IRMAA thresholds in advance. You can check where a given year lands with our free IRMAA calculator.

How the filing actually works

Step 1: Establish the event

The form asks which event applies and when it happened. For retirement, that is your last day of work. You do not need to wait for a premium notice to file: if the event has already happened and you know the lookback year is inflated, you can file when you enroll in Medicare.

Step 2: Estimate your income

This is where filings succeed or fail. You provide your estimate of MAGI for the current year, and optionally for next year if the reduction will show up then. Two things trip people up. First, severance and payouts count in the year you receive them, so if you retired in March and a severance payment landed in April, this year's estimate may not be low at all, and the real drop belongs in next year's estimate. Second, MAGI includes more than salary: interest, dividends, capital gains, pension payments, and any Roth conversions all count. An estimate that quietly omits these gets reconciled against your actual tax return later, and you will owe the difference.

Step 3: Provide evidence

For a work stoppage, the strongest evidence is a letter from your former employer confirming your last day, or documents that show the retirement happened, such as a severance agreement or pension award letter. The form also accepts a signed statement under penalty of perjury. Bring the evidence with the form.

Step 4: Submit and follow up

You can file at your local Social Security office in person, by mail, or by calling SSA to start the process. If approved, your premium is adjusted and any surcharge you already overpaid is refunded. One more thing people miss: the determination is annual. If next year's premium is again based on a high lookback year, you may need to file again for that year.

The mistakes that get filings denied

• An income estimate that ignores the severance year. If money from your package is still landing this year, say so and put the real drop in the right year's estimate.
• Only one spouse filing. IRMAA is charged per person. Each spouse on Medicare files their own SSA-44, even though the income on both forms is the same joint MAGI.
• No evidence attached. A form without documentation of the event invites a denial.
• Not updating a changed estimate. If your actual income comes in materially different from your estimate, tell SSA. They will reconcile against your tax return either way, and surprises run in both directions.
• Giving up after one denial. A denial can be appealed through a Request for Reconsideration, and many denials trace to fixable paperwork problems rather than actual ineligibility.

Where this fits in a real retirement plan

The SSA-44 is a repair tool. The better outcome is not needing it twice: sizing Roth conversions against the IRMAA tiers, spreading stock sales across years, and timing pension starts so that no single year breaches a threshold it did not need to. That is the planning we build for clients approaching Medicare, particularly those leaving SAP with an early retirement package or Vanguard with equity and deferred compensation. For the broader mechanics of the surcharge itself, see our IRMAA explainer.