IRMAA Retro Billing for 2018 and 2019

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Mitchell777
Posts: 1080
Joined: Mon May 21, 2007 6:32 am

IRMAA Retro Billing for 2018 and 2019

Post by Mitchell777 » Fri Nov 08, 2019 1:58 pm

Thought I understood how IRMAA works but guess I do not.

2016: Worked all year – MAGI < $85K (single) excl wages
2017: Retired 3/31 – MAGI < $85K (single) excl wages (went onto COBRA until Oct 2018, then Medicare)
2018: MAGI > $107K threshold (single) due to unexpected large CG distributions

For 2018 and 2019 Medicare fees I completed the one-time event paperwork and was accepted so no IRMAA fees have been charged for 2018 and 2019.

Rec’d letters today from Medicare explaining they will retro bill me IRMAA for both 2018 and 2019 Medicare Parts B/D.
For 2018 they are using the actual MAGI for 2018 rec’d from the IRS
For 2019 they compared my 2017 actual MAGI incl wages vs. 2018 actual MAGI from IRS and they used 2017 MAGI incl wages since it is very slightly below 2018 actual MAGI

I did not realize they retro billed but if they did I thought for 2018 they would use 2016 MAGI minus wages and for 2019 they would use 2017 MAGI minus wages

Has anyone been though this and how did it work? - Thanks

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One Ping
Posts: 766
Joined: Thu Sep 24, 2015 4:53 pm

Re: IRMAA Retro Billing for 2018 and 2019

Post by One Ping » Fri Nov 08, 2019 3:13 pm

Mitchell777 wrote:
Fri Nov 08, 2019 1:58 pm
Thought I understood how IRMAA works but guess I do not.

2016: Worked all year – MAGI < $85K (single) excl wages
2017: Retired 3/31 – MAGI < $85K (single) excl wages (went onto COBRA until Oct 2018, then Medicare)
2018: MAGI > $107K threshold (single) due to unexpected large CG distributions

For 2018 and 2019 Medicare fees I completed the one-time event paperwork and was accepted so no IRMAA fees have been charged for 2018 and 2019.

Rec’d letters today from Medicare explaining they will retro bill me IRMAA for both 2018 and 2019 Medicare Parts B/D.
For 2018 they are using the actual MAGI for 2018 rec’d from the IRS
For 2019 they compared my 2017 actual MAGI incl wages vs. 2018 actual MAGI from IRS and they used 2017 MAGI incl wages since it is very slightly below 2018 actual MAGI

I did not realize they retro billed but if they did I thought for 2018 they would use 2016 MAGI minus wages and for 2019 they would use 2017 MAGI minus wages

Has anyone been though this and how did it work? - Thanks
Medicare MAGI = adjusted gross income + tax exempt interest.

Don't know why you would "excl" (exclude?) wages from your adjusted gross income. What do your tax returns say was your adjusted gross income + tax exempt interest for 2016, 2017 and 2018?

Also, a given year's IRMAA is based on the Medicare MAGI from 2 years previous. For example, your IRMAA (if any) for 2017 would be based on your Medicare MAGI from 2015. 2018 was based on 2016 MAGI and 2019 on 2017 MAGI.

Since you retired in 2017 you may be able to apply for an exemption based on a "life changing event."
"Re-verify our range to target ... one ping only."

FactualFran
Posts: 915
Joined: Sat Feb 21, 2015 2:29 pm

Re: IRMAA Retro Billing for 2018 and 2019

Post by FactualFran » Fri Nov 08, 2019 4:04 pm

You were granted an exception for 2018 and 2019 on the grounds that you would not have the wage income you had in 2016 and 2017. However, the actual MAGI for 2018 was above an IRMAA threshold. On its face, the actual MAGI for 2018 indicates that the exceptions were not valid.

You could appeal the IRMAA for 2018 and 2019 because the reason for the exceptions was valid when you applied for the exceptions. However, after applying for the exception you had unexpected income for 2018. Likely, you will have to make a strong case that you made a good faith effort to provide accurate MAGI estimates. However, a good faith effort may not be enough to win the appeal.
Last edited by FactualFran on Fri Nov 08, 2019 4:18 pm, edited 1 time in total.

Topic Author
Mitchell777
Posts: 1080
Joined: Mon May 21, 2007 6:32 am

Re: IRMAA Retro Billing for 2018 and 2019

Post by Mitchell777 » Fri Nov 08, 2019 4:17 pm

One Ping wrote:
Fri Nov 08, 2019 3:13 pm
Mitchell777 wrote:
Fri Nov 08, 2019 1:58 pm
Thought I understood how IRMAA works but guess I do not.

2016: Worked all year – MAGI < $85K (single) excl wages
2017: Retired 3/31 – MAGI < $85K (single) excl wages (went onto COBRA until Oct 2018, then Medicare)
2018: MAGI > $107K threshold (single) due to unexpected large CG distributions

For 2018 and 2019 Medicare fees I completed the one-time event paperwork and was accepted so no IRMAA fees have been charged for 2018 and 2019.

Rec’d letters today from Medicare explaining they will retro bill me IRMAA for both 2018 and 2019 Medicare Parts B/D.
For 2018 they are using the actual MAGI for 2018 rec’d from the IRS
For 2019 they compared my 2017 actual MAGI incl wages vs. 2018 actual MAGI from IRS and they used 2017 MAGI incl wages since it is very slightly below 2018 actual MAGI

I did not realize they retro billed but if they did I thought for 2018 they would use 2016 MAGI minus wages and for 2019 they would use 2017 MAGI minus wages

Has anyone been though this and how did it work? - Thanks
Medicare MAGI = adjusted gross income + tax exempt interest.

Don't know why you would "excl" (exclude?) wages from your adjusted gross income. What do your tax returns say was your adjusted gross income + tax exempt interest for 2016, 2017 and 2018?

Also, a given year's IRMAA is based on the Medicare MAGI from 2 years previous. For example, your IRMAA (if any) for 2017 would be based on your Medicare MAGI from 2015. 2018 was based on 2016 MAGI and 2019 on 2017 MAGI.

Since you retired in 2017 you may be able to apply for an exemption based on a "life changing event."
As noted I did apply for a life changing event for both 2018 (using 2016 MAGI) and 2019 (using 2017 MAGI) Medicare B/D. Both were accepted. That is the reason I provided the MAGI minus wages. Yes, with wages I would have been above $85K. Excl wages, below $85K.

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