Can I be assessed Part D IRMAA if I am not enrolled in a Medicare drug plan?

No.  You should not pay an Income-Related Monthly Adjustment Amount (IRMAA) for Medicare Part D if you are not enrolled in a Medicare Part D drug plan (for example, you have no drug coverage or you get your supplemental drug coverage through the VA or Tricare).

As noted by the Centers for Medicare and Medicaid Services (CMS):

"If an individual does not have or no longer has Medicare prescription drug coverage, they shouldn’t be charged the Part D-IRMAA."

And when your Part D IRMAA is wrongly assessed...

If the Social Security Administration has made an error when assessing you Part D (or Part B) IRMAA - or if you have had a change in financial status and no longer fall into the annual IRMAA categories, you might consider appealing your IRMAA or asking for a reconsideration of your IRMAA.

We have information online about appealing IRMAA
on this site

and
on this site

Question:  But, I do not have a Medicare drug plan so why am I still paying Part D IRMAA?

You actually have Medicare Part D drug coverage in another form.

Quite often people are assessed Part D IRMAA because they are actually enrolled in some form of “supplemental” prescription drug coverage that is equivalent to a Medicare Part D plan.

For example, if you are enrolled in a prescription drug plan through a Medicare Advantage plan (MAPD) - or an employer health or drug plan - or union health plan - or retiree healthcare coverage - you will need to pay Part D IRMAA, if your plan includes "creditable" prescription drug coverage.

Question:  I really do not have any drug coverage, so why am I getting the IRMAA assessment?

You may have mistaken your Part B IRMAA payment for a Part D IRMAA assessment.

If you are a higher-earning Medicare beneficiary and enrolled in Medicare Part B, you will also be charged IRMAA for your Medicare Part B coverage - and sometimes people without any drug coverage mistake their Part B IRMAA payment for a Part D IRMAA assessment.

Question:  Why did I receive a bill for IRMAA even though I disenrolled from my Medicare drug plan?

It is possible that you are still paying your past-due Part D IRMAA from a previous Medicare drug plan.

The same CMS memo noted above continues on to note that "if someone didn’t pay the Part D-IRMAA that was owed before disenrolling from their prescription drug coverage, they are responsible for the past due amount."

So if you did not pay your past IRMAA for your Medicare Part D plan coverage, you can still be assessed Part D IRMAA for the unpaid portion or past-due IRMAA - even though you are no longer enrolled in a Medicare Part D plan.

See the related Frequently Asked Question:

Can I be disenrolled from my Medicare prescription drug plan if I refuse to pay my Medicare Part D IRMAA?

(Spoiler Alert:..  Yes.)

Need further assistance?

If you still need more information about the income-related monthly adjustment amounts (IRMAA), you can visit a local Social Security office or visit www.socialsecurity.gov/mediinfo.htm, or call Social Security at 1-800-772-1213 (TTY 1-800-325-0778).

Sources include:
Part D-Income Related Monthly Adjustment Amount—Frequently Asked Questions & Answers, from Anthony Culotta, Director Medicare Enrollment & Appeals Group, December 10, 2010)