When an IRMAA letter arrives, many people assume they have to “appeal.” Often they don't. Social Security has two separate tools. A new initial determination (usually requested with Form SSA-44) is a fresh decision based on newer information. A reconsideration is an appeal of the decision Social Security already made. They have different rules and deadlines, and you can use both.
Side by side
| SSA-44 (new initial determination) | Appeal (reconsideration) | |
|---|---|---|
| Use it when | Your income dropped because of one of the eight life-changing events | You believe the decision itself is wrong |
| Is it an appeal? | No. It's a new decision | Yes, the first of four levels |
| How to file | Form SSA-44 online, by fax or mail, at an appointment, or by phone. The form is optional | Online, Form SSA-561-U2, or your local office |
| Deadline | Any time in the year your income drops. October–December events: until March 31 of the next year | 60 days from when you receive the notice (assumed 5 days after its date) |
| What you need | Proof of the event and of your newer income | Your reasons, plus any documents that support them |
SSA-44: a new decision, not an appeal
Social Security calls this a new initial determination. It's a new decision that doesn't require reopening the old one (POMS HI 01120.001). If you qualify, there's no need to appeal. You can ask in writing or just by speaking with Social Security, so the SSA-44 form itself is optional.
The catch: it only works for the eight qualifying life-changing events, and the drop has to lower or end your IRMAA. One-time spikes like capital gains or an IRA conversion don't qualify. See the SSA-44 instructions for how to fill it out.
If Social Security dismisses the request, that dismissal can't be appealed (20 CFR 418.1310). But it does open a door, explained below.
See if an SSA-44 could lower your IRMAA. Start the free IRMAA check →
Reconsideration: when the decision itself is wrong
An appeal fits when you're not asking about newer income. You're saying the decision was wrong. One example from Social Security's manual: the IRS information is correct, but the wrong IRMAA level was applied or the MAGI was computed incorrectly (POMS HI 01140.005).
Example: You're single, and your 2026 letter shows 2024 MAGI of exactly $171,000, but charges $527.50 for Part B. The 2026 row “above $137,000 up to $171,000” includes $171,000, so the right amounts are $405.80 for Part B and $37.50 for Part D, not $527.50 and $60.40. That's a $144.60-a-month difference, and a clear case for reconsideration. Check the edges on our 2026 IRMAA brackets page.
You can file online, use Form SSA-561-U2, or contact your local office. Social Security's manual says it must accept an appeal if you want to file one, and can't discourage you.
60 days, counted from receipt
You have 60 days from when you receive the notice. Social Security assumes you received it 5 days after the date printed on it, unless you show otherwise (POMS HI 01140.001).
You can do both at the same time
You can file an appeal and an SSA-44 request together, as long as you're within the appeal period (POMS HI 01120.001). Social Security notes that in most situations a new initial determination gets the same result as an appeal, so an appeal isn't necessary. Filing both can still be sensible if you're close to the 60-day mark and unsure which applies.
There's also a safety net. Say you asked for a new initial determination instead of an appeal, based on Social Security's explanation of your options. It was denied or dismissed, and the 60 days have now passed. Social Security will find good cause to accept a late appeal (POMS HI 01140.005).
If the IRS number is wrong, neither one is the first step
If you think the IRS gave Social Security the wrong figure, fix it with the IRS first (1-800-829-1040). An appeal based only on that will be dismissed, and Social Security will tell you to get proof of the correction from the IRS (20 CFR 418.1330). Once you have that proof, ask Social Security for a new initial determination. For an amended return, call 1-800-772-1213. Social Security will need the amended return and the IRS's acknowledgment.
The four levels of IRMAA appeal
- Reconsideration by Social Security
- A hearing before an Administrative Law Judge in the Office of Medicare Hearings and Appeals (Department of Health and Human Services)
- Review by the Medicare Appeals Council
- Federal court
The October–December exception
Normally a new initial determination doesn't reach back into an earlier premium year. The exception: the event happens in the last three months of a year, and Social Security gets your request for that year by March 31 of the next year. Late requests can be accepted with good cause (POMS HI 01120.005).
Example: You stop working in November 2026, and that significantly lowers your 2026 income. You have until March 31, 2027 to ask Social Security to adjust your 2026 IRMAA.
Which one should you use?
- Your income dropped because of a qualifying event: SSA-44.
- The IRS figure is wrong: the IRS first, then a new initial determination.
- The IRS figure is right but the decision isn't (wrong tier or wrong math): an appeal within 60 days.
- Not sure, and the deadline is close: file both.
Still deciding? Read what to do when you get an IRMAA letter, or run the free IRMAA and SSA-44 check to see whether your event qualifies.