IRMAA: The Medicare Surcharge High Earners Need to Plan For

IRMAA: The Medicare Surcharge High Earners Need to Plan For

Whether Roth IRA withdrawals count as income for IRMAA depends on one distinction: a qualified Roth withdrawal is tax-free and stays out of the Medicare income calculation, while a Roth conversion is ordinary income and does count. This guide separates the two, shows exactly what feeds your IRMAA MAGI in 2026, and explains how retirees use Roth accounts to stay under the surcharge thresholds.

Last reviewed: August 2026 | Written and reviewed by Craig Wear, CFP®, founder of Q3 Advisors

No, qualified Roth IRA withdrawals do not count as income for IRMAA. Because a qualified Roth distribution is tax-free, it never enters your Adjusted Gross Income and therefore never raises the Modified Adjusted Gross Income (MAGI) that Medicare uses to set your Part B and Part D surcharges. A Roth conversion is different: the converted amount is taxable ordinary income and does count toward IRMAA.

Do Roth IRA withdrawals count as income for IRMAA?

Qualified Roth IRA withdrawals do not count as income for IRMAA. Medicare’s Income-Related Monthly Adjustment Amount is driven by MAGI, and a qualified Roth distribution is federally tax-free, so it is excluded from Adjusted Gross Income entirely. Traditional IRA and 401(k) withdrawals, by contrast, are taxable and do raise your IRMAA MAGI. The account type, not the withdrawal itself, decides the outcome.

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IRMAA is a means-tested surcharge the Social Security Administration adds on top of standard Medicare Part B and Part D premiums for beneficiaries whose income exceeds set thresholds. It is calculated from your MAGI two years earlier, so your 2026 premiums come from your 2024 tax return.

Money you already paid income tax on is not taxed again when it leaves a Roth IRA, so it produces no IRMAA. Traditional IRA dollars work the opposite way: every dollar withdrawn is taxable and lands in the same MAGI figure that sets your surcharge tier.

How is IRMAA income (MAGI) actually calculated?

For IRMAA, MAGI equals your Adjusted Gross Income from Form 1040, Line 11, plus any tax-exempt interest from Line 2a. There is no separate IRMAA worksheet. The Social Security Administration pulls these two numbers from the tax return the IRS shares with it, uses the return from two years prior, and compares the total to the annual threshold table to assign your tier.

Because IRMAA starts from AGI, anything that raises AGI raises your surcharge exposure, and anything excluded from AGI stays out of it. The one twist is the tax-exempt interest add-back: municipal bond interest is free of federal income tax but still counts for IRMAA.

What income counts toward IRMAA MAGI?

Income that counts toward IRMAA MAGI includes traditional IRA and 401(k) withdrawals, required minimum distributions, Roth conversions, pensions and annuity payments, wages, capital gains, qualified and ordinary dividends, rental income, the taxable portion of Social Security, and tax-exempt municipal bond interest. Each of these either sits in your AGI or is added back on Line 2a, so each can push you toward a higher Medicare surcharge tier.

  • Traditional IRA and 401(k) distributions, including RMDs starting at age 73
  • Roth conversions (the taxable converted amount)
  • Pension, annuity, and deferred-compensation payments
  • Capital gains, dividends, and interest from CDs and taxable bonds
  • The taxable portion of Social Security benefits
  • Tax-exempt municipal bond interest (added back on Line 2a)

What income does NOT count toward IRMAA?

Income excluded from IRMAA MAGI includes qualified Roth IRA and Roth 401(k) withdrawals, Health Savings Account distributions for qualified medical costs, the return of your own after-tax cost basis, life insurance proceeds, and loan proceeds. Above-the-line deductions such as HSA contributions lower AGI and therefore lower IRMAA MAGI. These excluded sources are the levers retirees use to keep MAGI under a threshold.

Retirement income source Counts toward IRMAA MAGI?
Qualified Roth IRA withdrawal No
Qualified Roth 401(k) withdrawal No
Traditional IRA / 401(k) withdrawal or RMD Yes
Roth conversion (taxable amount) Yes
HSA withdrawal for qualified medical costs No
Municipal bond interest Yes (added back)
Taxable portion of Social Security Yes

Why qualified Roth IRA withdrawals stay out of your IRMAA calculation

Qualified Roth IRA withdrawals stay out of your IRMAA calculation because they are 100% federally tax-free and never appear in Adjusted Gross Income. IRMAA is built from AGI plus tax-exempt interest, and a qualified Roth distribution belongs to neither line. This is the mechanical reason Roth assets can fund a comfortable retirement without lifting your Medicare premiums a single dollar.

One nuance most explanations skip: the exclusion applies only to distributions that are actually qualified. A Roth withdrawal that fails the qualification tests can have a taxable portion, and that portion enters your AGI and your IRMAA MAGI. Knowing what makes a withdrawal qualified is the difference between a tax-free retirement paycheck and an accidental surcharge trigger.

What makes a Roth withdrawal “qualified” (5-year rule and age 59.5)?

A Roth IRA withdrawal is qualified when it meets two tests at once: the account has been open for at least five tax years (the 5-year rule), and you are at least age 59.5 (or the withdrawal is due to death, disability, or a first home). Meet both and the entire distribution, including all earnings, is tax-free and excluded from IRMAA MAGI.

The 5-year clock starts on January 1 of the tax year of your first Roth contribution, and it applies once per person, not once per account. Someone who opened their first Roth IRA at age 60 cannot take fully qualified earnings until age 65, because the five-year window has not closed even though they clear the age test.

When can a non-qualified Roth withdrawal still raise your MAGI?

A non-qualified Roth withdrawal raises your MAGI only to the extent it distributes earnings. Under IRS ordering rules, contributions come out first and are always tax-free, followed by conversion amounts, and finally earnings. If a withdrawal reaches the earnings layer before you meet the 5-year rule and age 59.5, that earnings portion is taxable ordinary income and counts toward IRMAA MAGI.

For a retiree over 59.5 with a Roth open more than five years, this risk is zero because every distribution is qualified. The exposure appears mainly for early retirees who tap earnings before both tests are met; withdrawing only up to your contribution and conversion basis keeps a non-qualified distribution out of your MAGI.

But do Roth conversions count toward IRMAA? (yes, and here’s the trap)

Yes, Roth conversions count toward IRMAA. When you convert traditional IRA dollars to a Roth IRA, the converted amount is taxable ordinary income in the conversion year, so it lands in your AGI and your IRMAA MAGI. A conversion can therefore push you into a higher Medicare surcharge tier two years later, even though the Roth withdrawals it eventually funds will be tax-free.

The same Roth account that keeps future IRMAA low is filled by conversions that can raise IRMAA in the conversion year. A multi-year Roth conversion plan controls conversion size and timing so the short-term surcharge stays smaller than the lifetime savings from lower future RMDs. We model the trade-off in the Roth conversion break-even analysis and size annual amounts in our guidance on how much to convert to Roth.

The two-year lookback: how a 2026 conversion hits your 2028 Medicare premiums

Medicare uses a two-year lookback, so a Roth conversion completed in 2026 is reported on your 2026 tax return and sets your 2028 IRMAA tier. The Social Security Administration does not react to conversions in real time; it waits for the IRS to share the return two years later. Plan the conversion year around the premium year it will control, not the year you convert.

A Roth conversion must be completed by December 31 to count for that tax year, and it is irreversible, with no undo after year-end. You also cannot convert a required minimum distribution: the RMD must come out first, and only dollars above it can be converted. Timing conversions during lower-income years keeps the lookback impact contained.

Why converting before age 63 can dodge the IRMAA lookback

Converting before age 63 can keep a conversion out of the IRMAA calculation because of the two-year lookback. Most people enroll in Medicare at 65, and their first IRMAA year is set by income from age 63. The last conversion year that never affects any Medicare premium is age 62, so conversions completed at 62 or younger escape the IRMAA lookback for the standard enrollment timeline.

This makes the late-50s-to-early-60s window valuable for Roth conversion planning. In those years, many investors have left work but not yet started Social Security or RMDs, so their MAGI is low and conversions can be done at favorable brackets with no Medicare surcharge consequence. Coordinating that window with the annual conversion deadline is a common step.

How to use Roth accounts to reduce or eliminate IRMAA in retirement

Roth accounts reduce IRMAA by replacing taxable traditional IRA withdrawals with tax-free Roth withdrawals that never enter MAGI. Filling Roth accounts through conversions before age 63 and during low-income years shrinks future required minimum distributions, and smaller RMDs mean a lower MAGI throughout retirement. A well-sequenced Roth strategy can keep many retirees under the first IRMAA threshold for years.

SECURE 2.0 strengthened this approach starting in 2024 by eliminating lifetime required minimum distributions from Roth 401(k) accounts. Roth 401(k) balances no longer force any distribution during the owner’s life, removing the taxable-adjacent pressure that traditional 401(k) RMDs create.

Several other levers work alongside Roth planning:

  1. Size Roth conversions to stay just below the next IRMAA threshold rather than converting a large lump sum at once.
  2. Use qualified charitable distributions from an IRA (age 70.5 and older) to satisfy an RMD without adding to MAGI. QCDs come only from an IRA, not a 401(k).
  3. Time capital gains so large asset sales do not stack on a high-income year, and watch the separate Net Investment Income Tax of 3.8% above $200,000 single or $250,000 joint.
  4. Draw from tax-free Roth and HSA sources in years when one more taxable dollar would cross a threshold.
  5. Coordinate conversions with your required minimum distribution schedule, since RMDs begin at age 73 (age 75 for those born in 1960 or later).

2026 IRMAA brackets at a glance

For 2026, IRMAA begins above $109,000 of MAGI for single filers and $218,000 for joint filers, using income from your 2024 tax return. The standard Part B premium is $202.90 per month, and IRMAA is added on top. IRMAA is a cliff: crossing a threshold by one dollar triggers the full next tier of surcharge for both Part B and Part D.

The table below shows the first two Part B tiers. A single filer at $109,000 pays $202.90 per month; one dollar more raises the total to $284.10, an extra $81.20 monthly or about $974 a year. For the full schedule, Part D figures, and married-filing-separately rules, see our guide to the 2026 Medicare IRMAA brackets and premiums.

2026 MAGI (single / joint) Monthly Part B IRMAA Total monthly Part B
Up to $109,000 / $218,000 $0 $202.90
$109,001 to $137,000 / $218,001 to $274,000 $81.20 $284.10

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Frequently asked questions

Do Roth IRA withdrawals affect Medicare premiums?

Qualified Roth IRA withdrawals do not affect Medicare premiums. They are federally tax-free, stay out of Adjusted Gross Income, and never enter the MAGI that determines IRMAA, so they cannot raise your Part B or Part D surcharge. Only the earnings portion of a non-qualified Roth withdrawal, taken before the 5-year rule and age 59.5 are met, could affect your premiums.

Can Roth IRA withdrawals affect IRMAA?

A qualified Roth IRA withdrawal cannot affect IRMAA, but a non-qualified one can to a limited degree. If you withdraw earnings before satisfying the 5-year rule and reaching age 59.5, that earnings portion is taxable and counts toward MAGI. Withdrawals limited to your contribution and conversion basis remain tax-free and stay out of IRMAA regardless of your age.

Do IRA and 401(k) withdrawals always increase Medicare premiums?

Traditional IRA and 401(k) withdrawals are taxable and add to MAGI, but they only increase Medicare premiums if the added income pushes your MAGI across an IRMAA threshold. A modest withdrawal that keeps you under $109,000 single or $218,000 joint in 2026 changes nothing. Roth IRA and qualified Roth 401(k) withdrawals do not add to MAGI at all.

Does a traditional IRA withdrawal count as earned income?

A traditional IRA withdrawal is not earned income; it is taxable ordinary income. The distinction matters for things like IRA contribution eligibility, which requires earned income, and for Social Security taxation rules. For IRMAA, the label does not change the outcome: a traditional IRA distribution is fully included in your MAGI and can raise your Medicare surcharge tier.

Can I lower my IRMAA if my income goes down after I retire?

Yes. If a qualifying life-changing event such as retirement, reduced work hours, divorce, or the death of a spouse lowers your income, you can file Form SSA-44 with the Social Security Administration to have a more recent year used for your IRMAA calculation. A Roth conversion by itself is not a qualifying event, so it cannot be appealed on its own.

Does a Roth conversion count toward IRMAA?

Yes, a Roth conversion counts toward IRMAA. The converted amount is taxable ordinary income in the conversion year, so it is included in that year’s MAGI and can move you into a higher Medicare surcharge tier two years later under the lookback. A conversion completed in 2026 affects your 2028 premiums, which is why conversion timing matters.

What income counts toward IRMAA MAGI?

IRMAA MAGI equals Adjusted Gross Income (Form 1040, Line 11) plus tax-exempt interest (Line 2a). It includes traditional IRA and 401(k) withdrawals, RMDs, Roth conversions, pensions, wages, capital gains, dividends, the taxable share of Social Security, and municipal bond interest. It excludes qualified Roth withdrawals and HSA distributions used for qualified medical expenses.

Q3 Advisors is a registered investment adviser. This content is educational and is not investment, tax, or legal advice. Registration does not imply a certain level of skill or training. Figures reflect 2026 IRS and Medicare guidance and may change; consult a qualified professional about your situation. Additional information is available in our Form ADV.

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