MAGI for IRMAA: What Income Counts
Last updated · Sources: CMS, SSA, BLS
IRMAA uses its own definition of modified adjusted gross income. Per SSA regulation 20 CFR 418.1010, MAGI is your adjusted gross income plus tax-exempt interest income, plus certain income excluded from AGI (such as excluded foreign earned income and certain income from U.S. territories).
Commonly included (through AGI)
- Wages and self-employment income
- Traditional IRA / 401(k) distributions, including required minimum distributions
- Roth conversions (the converted amount)
- Capital gains (including from selling a home above the exclusion), dividends, taxable interest
- The taxable portion of Social Security benefits
- Pension and annuity income, rental income
Commonly not included
- Qualified Roth IRA distributions
- Qualified HSA withdrawals for medical expenses
- Qualified charitable distributions (QCDs) from an IRA, which are excluded from income
- The non-taxable portion of Social Security
Which year? IRMAA usually looks at the tax return from two years before the premium year — see the two-year lookback. If income dropped because of a qualifying life event, you may appeal with Form SSA-44.
This is a general description; confirm your own situation with a tax professional.
Questions
Does municipal bond interest count toward IRMAA?
Yes. Tax-exempt interest (Form 1040 line 2a) is added back to AGI when computing MAGI for IRMAA.
Do Roth IRA withdrawals count toward IRMAA?
Qualified Roth distributions are not included in AGI, so they do not raise IRMAA MAGI. A Roth conversion does count in the year of conversion.
Does Social Security income count?
Only the taxable portion of Social Security benefits, because that portion is part of AGI.