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Can I be assessed an Income Related Monthly Adjustment Amount (IRMAA) if I am enrolled in my employer's Medicare drug plan?


Yes.  If your  annual income (MAGI) exceeds certain limits - and you are enrolled in an employer-sponsored Medicare Part D prescription drug plan (PDP) or Medicare Advantage plan with prescription drug coverage (MAPD), then you can be charged an Income-Related Monthly Adjustment Amount (IRMAA) for your Medicare Part D coverage -- and you are also responsible for paying Part B-IRMAA if you are receiving Medicare Part B coverage.

In more general terms:  If you are a high-earning Medicare beneficiary and have some form of “supplemental” prescription drug policy or prescription drug plan through an employer health plan, union health plan, or retiree healthcare coverage – your drug coverage may actually be considered equivalent to a Medicare Part D drug plan and you will be assessed Part D IRMAA.  You can telephone your health plan administrator for more information about your employer, union-sponsored, or retiree drug coverage.

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

"Employer/Union coverage and Part D-IRMAA

You pay your [Medicare] Part D-IRMAA directly to Medicare, not to your plan or employer.

You’re required to pay the [Medicare] Part D-IRMAA, even if your employer or a third party (like a teacher’s union or a retirement system) pays for your Part D plan premiums.  If you don’t pay the Part D-IRMAA and get disenrolled, you may also lose your retirement coverage and you may not be able to get it back."

(https://www.medicare.gov/part-d/costs/premiums/drug-plan-premiums.html)

What is considered "income" when determining IRMAA?

Your MAGI or modified adjusted gross income from two years ago - meaning the Social Security Administration (SSA) will try to use your most recent tax return showing MAGI from the previous year.  For example, your 2020 IRMAA will be determined using your most recent tax return filed in 2019 that is reporting your 2018 MAGI.  It is possible that the IRS provides older tax returns to the SSA if the most recent tax return is not available.

Appealing IRMAA or asking the SSA for an IRMAA Reconsideration

If your income has changed since the filing of this older tax return - or you have experienced certain life changing events - you have the right to ask the SSA for an IRMAA reconsideration.

We have information online about appealing IRMAA here: https://Q1FAQ.com/544.html and here:
https://q1medicare.com/PartD-IRMAAReconsiderationAppealsPartD.php

For more information about appealing your IRMAA, you can visit a local Social Security office or review the Social Security IRMAA site https://www.ssa.gov/OP_Home/handbook/handbook.25/handbook-2500.html, or call Social Security at 1-800-772-1213 (TTY 1-800-325-0778).

See also:
https://www.ssa.gov/pubs/EN-05-10536.pdf





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  • When enrolling in a Medicare Advantage plan, you must continue to pay your Medicare Part B premium.
  • Medicare beneficiaries with higher incomes may be required to pay both a Medicare Part B and Medicare Part D Income Related Monthly Adjustment Amount (IRMAA). Read more on IRMAA.
  • Medicare Advantage plans that include prescription drug coverage (MAPDs) are considered Medicare Part D plans and members with higher incomes may be subject to the Medicare Part D Income Related Monthly Adjustment Amount (IRMAA), just as members in stand-alone Part D plans. In certain situations, you can appeal IRMAA.
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