Roth Conversion and Medicaid: Income Test vs. Asset Test (2026)

Roth Conversion and Medicaid: Income Test vs. Asset Test (2026)

Whether a Roth IRA affects Medicaid eligibility depends entirely on which Medicaid you mean: for long-term-care Medicaid the Roth balance is generally a countable asset that can block eligibility, while for income-based (MAGI) Medicaid there is no asset test at all and only the income you report in a given year matters. Owning or converting to a Roth is read through one of two separate doors, and confusing them is the most common planning error.

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

Does a Roth IRA affect Medicaid eligibility? For long-term-care Medicaid, yes: in most states the Roth balance is a countable asset measured against the SSI resource limit, generally $2,000 for an individual and $3,000 for a couple (Source: CRS Report R43506). For MAGI-based Medicaid, the balance is irrelevant because 42 CFR 435.603 applies no asset test; only conversion-year income can matter.

How a Roth conversion affects Medicaid depends on which Medicaid you mean

Medicaid uses two separate financial-eligibility methods, and a Roth IRA or a Roth conversion hits each differently. MAGI-based Medicaid counts only income and applies no asset test. Long-term-care and aged, blind, or disabled Medicaid apply both an income standard and an asset test (Source: 42 CFR 435.603, Cornell LII). Identifying which pathway applies answers most of the question.

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Under 42 CFR 435.603, most non-elderly enrollees (children, adults age 19 to 64, parents, and pregnant women) qualify through the MAGI-based method, which uses the Affordable Care Act income definition and, by rule, must not apply any assets or resources test (Source: 42 CFR 435.603(e) and (g)). The method does not apply to people age 65 or older where age is a condition of eligibility, people eligible on the basis of blindness or disability, or people seeking long-term services and supports; those groups use SSI-based rules that add a resource test (Source: 42 CFR 435.603(j)). That asset test is where a Roth IRA becomes a live issue.

Does a Roth IRA count as an asset for Medicaid?

For long-term-care Medicaid, a Roth IRA generally counts as an available asset in most states, measured against a resource limit of roughly $2,000 for an individual and $3,000 for a couple (Source: CRS Report R43506). For MAGI-based Medicaid, a Roth IRA does not count at all, because that pathway applies no asset test (Source: 42 CFR 435.603(e) and (g)). The pathway determines the answer.

The elder-law consensus is that a Roth IRA is usually a countable resource for long-term-care Medicaid. Federal rules require an applicant to liquidate all available resources unless there is a specific exemption (Source: CRS Reports R43506 and RL33593), and a self-directed retirement account the owner can cash out is generally treated as available. Because the asset limit sits at $2,000 for an individual and $3,000 for a couple and has not changed since 1989 (Source: CRS Report R43506), even a modest Roth balance can exceed it.

Why Roth IRAs are usually countable (no lifetime RMDs means no payout status)

Roth IRAs are usually countable because they have no lifetime required minimum distributions for the owner, so they cannot be placed in payout status. Several states exempt a traditional IRA once the owner is taking required minimum distributions and count only the income stream. A Roth owner cannot access that exemption because there is no mandatory distribution to point to (Source: IRS Pub 590-B, 2025).

A traditional IRA forces distributions starting at the required beginning age (age 73, or age 75 for those born in 1960 or later, with the first age-75 required year arriving in 2035), and some states exempt an account throwing off those mandated payments, counting only the payments (Source: IRS Pub 590-B, 2025). A Roth IRA has no lifetime required minimum distributions for the original owner, so nothing converts it to payout status and the full balance stays countable. Q3 Advisors covers the timing in its guide to 2026 required minimum distributions.

How states differ (payout-status exemptions, spousal exemptions, AZ, PA, and OH examples)

State treatment of retirement accounts for long-term-care Medicaid varies widely and is fixed by each state Medicaid manual, not a single federal rule. Some states count a Roth IRA in full, some exempt an account only when it is in periodic-payment status, and a community-spouse resource allowance can shelter part of a couple’s assets. Confirming treatment requires the applicable state manual.

State approach Example states How a Roth IRA is generally treated
Count the balance regardless of payment status Arizona, Pennsylvania The Roth balance counts as an available resource even if the owner is taking periodic payments
Exempt when in periodic-payment status Ohio A Roth can be exempt if the owner takes regular periodic payments, which is hard to arrange for a Roth with no mandated distribution
Exempt a traditional IRA in RMD status, count only income Florida, Georgia, New York Traditional IRA in RMD status is not counted as an asset; a Roth lacks that RMD stream, so treatment differs
Community-spouse resource allowance All states, federally set range A portion of a couple’s countable assets can be protected for the non-applicant spouse, adjusted annually

The same Roth IRA can be fully countable in Arizona or Pennsylvania yet treated differently in a payout-status state such as Ohio, so anyone planning for care should confirm the rule in their own state and consult an elder-law attorney.

Why a Roth conversion is a taxable, MAGI-raising event

A Roth conversion is fully taxable in the year it happens, and the IRS treats the converted amount as includible in gross income. That income flows through adjusted gross income into modified adjusted gross income, the figure many benefit programs read. So a conversion raises MAGI for MAGI-Medicaid, ACA premium tax credits, and Medicare IRMAA in the conversion year (Source: IRS Pub 590-A, 2025).

A conversion is uncapped, has a December 31 completion deadline, and cannot include a required minimum distribution (Source: IRS Pub 590-A, 2025). It is also hard to undo: a conversion made in 2018 or later cannot be recharacterized, so it cannot be reversed once done (Source: IRS Pub 590-B, 2025, reflecting the Tax Cuts and Jobs Act). Because a Roth conversion generally cannot be walked back, its size and timing matter, as covered in the Q3 Advisors piece on how much to convert to a Roth.

Roth conversion and MAGI-Medicaid: the conversion-year income problem

For anyone who qualifies through MAGI-based Medicaid, a Roth conversion raises countable income in the conversion year and can affect eligibility for that year. The MAGI method uses the ACA income definition and applies no asset test (Source: 42 CFR 435.603(e) and (g)), so the risk here is the conversion-year income spike, not the size of the Roth balance.

MAGI-Medicaid income thresholds are set as a percentage of the federal poverty line and vary by state and category, so the federal rule fixes only the methodology, not one national dollar cutoff. The same conversion-year spike also reaches the ACA marketplace for people under 65: premium-tax-credit MAGI includes conversion income (Source: 26 U.S.C. 36B(d)(2)(B)), and the 400%-of-poverty subsidy cliff returns for tax year 2026 with no repayment cap for years after 2025 (Source: IRS, Eligibility for the Premium Tax Credit). A 2026 conversion that lifts MAGI over that line can end the subsidy and force full repayment of advance credits.

Roth conversion and long-term-care Medicaid: it is the asset test that governs

For long-term-care Medicaid, eligibility turns on an asset test, not conversion-year income. A Roth conversion changes the account’s tax character; it does not change whether the dollars are a countable asset. A conversion is not a spend-down, and a conversion inside a Medicaid look-back window does not remove the asset from the count (Source: CRS Report R43506).

This is the point most articles miss. If the traditional IRA would have been counted, converting the same dollars into a Roth IRA leaves an asset of the same value inside the household, only with a different tax label. Federal law still requires liquidating available resources unless exempt (Source: CRS Report R43506), and whether a retirement account is counted or exempt is state-specific, so confirming treatment requires the applicable state Medicaid manual and, for care planning, an elder-law attorney.

The two Medicaid pathways side by side

The two Medicaid financial-eligibility methods respond to a Roth IRA differently. MAGI-based Medicaid counts conversion-year income and applies no asset test, while long-term-care and aged, blind, or disabled Medicaid apply an asset test where the account balance itself is the main concern. Which pathway applies depends on age, disability status, and whether long-term care is involved (Source: 42 CFR 435.603(j)).

Feature MAGI-based Medicaid Long-term-care / aged-blind-disabled Medicaid
Who it covers Children, adults 19 to 64, parents, pregnant women Age 65+, blind or disabled, and those seeking nursing-facility or HCBS care
Income test Yes, ACA MAGI methodology Yes, SSI-based income standard
Asset (resource) test No asset test applied Yes, generally $2,000 individual / $3,000 couple
Is a Roth IRA balance counted? No, balance is irrelevant Yes in most states, as an available resource
Main Roth risk Conversion-year income spike The account balance itself as a countable asset
Federal source 42 CFR 435.603(e),(g) 42 CFR 435.603(j); CRS R43506

Roth conversion and Medicare IRMAA: the delayed hit at 65 and older

People age 65 and older can see a Roth conversion raise Medicare premiums about two years later through the income-related monthly adjustment amount, or IRMAA. IRMAA uses a two-year MAGI lookback, so 2026 Part B and Part D surcharges rest on the 2024 tax return (Source: SSA POMS HI 01101.020). It is a cliff: a dollar over a bracket edge raises the whole tier.

Because of that lag, the last conversion year that does not affect a future Medicare premium is age 62. The 2026 standard Part B premium is $202.90, up $17.90 from $185.00 in 2025 (Source: CMS, 2026 Medicare Parts A and B Premiums and Deductibles), and the surcharge tiers stack above that base.

2026 MAGI, single return 2026 MAGI, married filing jointly Total monthly Part B premium
$109,000 or less $218,000 or less $202.90 (no IRMAA)
Above $109,000 to $137,000 Above $218,000 to $274,000 $284.10
Above $137,000 to $171,000 Above $274,000 to $342,000 $405.80
Above $171,000 to $205,000 Above $342,000 to $410,000 $527.50
Above $205,000 to below $500,000 Above $410,000 to below $750,000 $649.20
$500,000 or more $750,000 or more $689.90

Source: SSA POMS HI 01101.020 (2026 Part B tiers). Because IRMAA and Medicaid read different tests, a household can face the IRMAA surcharge (an income effect) without any change to long-term-care Medicaid eligibility (an asset effect).

How the conversion decision fits into broader retirement-tax timing

A Roth conversion is usually weighed against several thresholds in the same year: the ordinary income-tax bracket, the ACA subsidy cliff before 65, Medicare IRMAA after 65, and any Medicaid asset test that may apply later. Because a conversion cannot be reversed under post-2017 rules (Source: IRS Pub 590-B, 2025), the size and sequence of conversions is where planning attention usually goes.

These thresholds interact because they read different tests in different years: the tax bracket and ACA cliff respond to conversion-year income, IRMAA to that income two years later, and a Medicaid asset test years afterward on the balance. Related items such as the Roth conversion break-even point, the net investment income tax, and the 2026 conversion deadline can move in the same year, which is why many households model several years at once rather than a single conversion in isolation.

2026 figures that frame the conversion decision

Several 2026 figures set the boundaries around a conversion year. A Roth conversion itself has no income limit; the MAGI phase-outs below apply only to direct Roth contributions, not conversions. The IRA contribution limit is $7,500, the standard deduction is $16,100 single and $32,200 married filing jointly, and the Medicaid asset limit is generally $2,000 individual or $3,000 couple (Source: IRS Notice 2025-67; CRS Report R43506).

2026 item Amount Source
IRA contribution limit $7,500 (up from $7,000 in 2025) IRS Notice 2025-67
IRA total with age-50 catch-up $8,600 IRS Notice 2025-67
Roth contribution MAGI phase-out, single/HoH $153,000 to $168,000 IRS Notice 2025-67
Roth contribution MAGI phase-out, MFJ $242,000 to $252,000 IRS Notice 2025-67
Standard deduction, single/MFS $16,100 IRS Rev. Proc. 2025-32
Standard deduction, MFJ $32,200 IRS Rev. Proc. 2025-32
Medicare Part B standard premium $202.90 per month CMS 2026 fact sheet
Medicaid asset limit, individual / couple $2,000 / $3,000 CRS Report R43506

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Frequently asked questions

Does a Roth IRA count as an asset for Medicaid?

For long-term-care Medicaid, a Roth IRA generally counts as an available asset in most states, measured against a resource limit of roughly $2,000 for an individual and $3,000 for a couple (Source: CRS Report R43506). For MAGI-based Medicaid (children, adults 19 to 64, parents, pregnant women), it does not count at all, because that pathway applies no asset test (Source: 42 CFR 435.603).

Can I lose Medicaid if I convert to a Roth IRA?

You can, but through income, not the balance. A conversion is fully includible in gross income and raises modified adjusted gross income in the conversion year (Source: IRS Pub 590-A, 2025), which can affect MAGI-based Medicaid or an ACA subsidy for that year. It does not reduce a countable Roth balance, so it cannot rescue long-term-care Medicaid eligibility either.

How do I protect my IRA from Medicaid?

A Roth conversion does not shield an IRA from Medicaid, because it leaves an asset of equal value in the household (Source: CRS Report R43506). Genuine protection strategies (such as spend-down, a community-spouse resource allowance, or certain trusts) are state-specific, interact with the five-year lookback, and can carry tax and legal consequences. This planning belongs with a qualified elder-law attorney.

What assets are exempt from Medicaid?

Long-term-care Medicaid exempts specific resources rather than retirement accounts by default. Commonly exempt items include a primary residence up to an equity limit, one vehicle, personal belongings, and certain burial funds; a community-spouse resource allowance can shelter part of a couple’s assets (Source: CRS Reports R43506 and RL33593). Exemptions and dollar limits vary by state, so the state Medicaid manual controls.

Does a Roth conversion count as income for Medicaid?

For MAGI-based Medicaid, yes. A Roth conversion is fully includible in gross income and raises modified adjusted gross income in the conversion year (Source: IRS Pub 590-A, 2025), and MAGI-Medicaid counts that income with no asset test (Source: 42 CFR 435.603). For long-term-care Medicaid, the asset test, not conversion income, is the main factor.

What is the 5-year lookback rule for Medicaid?

The five-year lookback lets a state review asset transfers made in the 60 months before a long-term-care Medicaid application; gifts or below-market transfers in that window can trigger a penalty period. A Roth conversion is not a gift to another person, so it is generally not a lookback transfer by itself; the dollars stay in the applicant’s name at the same value (Source: CRS Report R43506).

Are retirement accounts counted for Medicaid?

For MAGI-based Medicaid, no retirement account is counted, because there is no asset test (Source: 42 CFR 435.603). For long-term-care Medicaid, retirement accounts are generally countable unless a state exempts an account in required-minimum-distribution or periodic-payment status. Because a Roth IRA has no lifetime RMDs for the owner, that payout-status exemption is often unavailable, so the Roth balance stays countable.

What is the Medicaid asset limit in 2026?

The SSI-based long-term-care Medicaid resource limit is generally $2,000 for an individual and $3,000 for a couple, a figure unchanged since 1989 (Source: CRS Report R43506). Some states set a higher couple limit, and a community-spouse resource allowance can protect additional assets. MAGI-based Medicaid has no asset limit at all (Source: 42 CFR 435.603).

Sources

IRS Publication 590-A (2025); IRS Publication 590-B (2025); IRS Notice 2025-67 (2026 retirement plan limits); IRS Rev. Proc. 2025-32 (2026 inflation adjustments); IRS, Eligibility for the Premium Tax Credit; 26 U.S.C. 36B(d)(2)(B); 42 CFR 435.603 (Cornell LII); CRS Report R43506 and CRS Report RL33593 (Medicaid financial eligibility); SSA POMS HI 01101.020 (IRMAA); CMS, 2026 Medicare Parts A and B Premiums and Deductibles.

About the author

Craig Wear, CFP®, is the founder of Q3 Advisors, a registered investment adviser focused on retirement tax planning and Roth conversion analysis. He writes on the tax rules that shape retirement-income decisions, including how income and asset tests interact with Medicare, Medicaid, and the ACA marketplace.

Disclaimer

This article is for informational and educational purposes only and is not investment, tax, or legal advice, nor a recommendation to take any specific action. Registration as an investment adviser does not imply a certain level of skill or training. Rules described here may change and their application depends on individual circumstances; figures are current as of the sources and years cited. Consult a qualified tax, legal, or financial professional about your own situation. Q3 Advisors is a registered investment adviser; additional information is available in its Form ADV.

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