IRMAA brackets 2026 + conversion planning

Updated: July 28, 2026

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A retired corporate executive with $1 to $3 million in rollover IRAs, deferred compensation, and post-NUA brokerage balances faces a key planning window between age 60 and 65. The Income-Related Monthly Adjustment Amount rule at 42 USC §1395r(i) turns each pre-Medicare tax year into a planning fulcrum.

Medicare premiums at age 65 are set by the modified adjusted gross income reported two years earlier. A household enrolling in 2028 sees its premium tier set by the 2026 federal return.

The bracket schedule is not a graduated phase-in: each tier is a hard cliff under 42 CFR §418.1115, where one dollar of MAGI above a threshold triggers the full incremental surcharge for the year. Both Medicare-enrolled spouses pay through monthly Social Security withholdings.

Element I of the multi-year sequence is the baseline MAGI projection: pension payments, deferred-compensation distributions on the §409A schedule, RSU vest events that have not yet cleared, residual W-2 income, taxable interest, and qualified dividends.

Element II is the conversion-sizing decision: how much of the rollover IRA balance moves into a Roth wrapper each calendar year, against which IRMAA tier boundary, with which tax-cost arithmetic. Element III is the destination-allocation question, including whether a sized self-directed metals sleeve under IRC §408(m) belongs inside the Roth at all.

For households evaluating a metals destination, it is worth screening any custodian and dealer against our 2026 list of gold IRA operators OPRS does not recommend before any conversion calendar is locked. The sections below cover each element in sequence.

The 2026 IRMAA bracket structure at a glance

The IRMAA tier schedule is set annually by CMS through the determination process documented at 42 CFR §418.1010 and the SSA operations manual at POMS HI 01101.010. Each year, CMS releases the next calendar year’s bracket dollar values in October. The October 2025 release set the 2026 schedule.

The tier count, the cliff geometry, and the two-year lookback are statutory at 42 USC §1395r(i) and carry forward unchanged year over year. Only the dollar breakpoints adjust for inflation under 42 USC §1395r(i)(5).

The most useful empirical anchor is the 2025 schedule, which is the one currently in effect for premiums billed in 2025 based on 2023 MAGI. The 2026 schedule applies the same six-tier structure with statutory inflation adjustments to the dollar thresholds; the cliff magnitudes scale similarly.

For a married-filing-jointly household, the 2025 breakpoints sit at $212,000, $266,000, $334,000, $400,000, and $750,000. The annual combined Part B plus Part D surcharge per couple at each tier is the figure that matters for the sizing arithmetic.

At $211,999 of MAGI, a married couple owes $0 in Part B IRMAA and $0 in Part D IRMAA for 2025. At $212,001, that same couple faces $2,092 in combined annual surcharge under the 2025 schedule.

Here is the cliff in concrete terms. A Roth conversion that pushes MAGI from $211,000 to $213,000 carries a hidden marginal cost of $2,092 for that single calendar year. That cost arrives through Medicare premium withholdings two years later, on top of the conversion’s federal income tax.

The 2026 schedule retains the same structure with inflation-adjusted thresholds; any household sizing conversions during 2026 against an age-65 enrollment in 2028 should pull the CMS October 2025 release for the exact applicable MAGI breakpoints.

Where this matters: CMS publishes the next-year bracket schedule each October. The October 2025 release is the source document for 2026 brackets. The October 2026 release will be the source document for 2027 brackets. Pulling the current CMS fact sheet at the start of each conversion-planning cycle is the discipline that keeps the arithmetic anchored to the actual schedule rather than to last year’s figures.

How the two-year lookback prices 2026 Medicare premiums

Two items from Form 1040 feed into IRMAA-specific MAGI: adjusted gross income (line 11) and tax-exempt interest (line 2a), as defined at 42 USC §1395r(i)(4). Because the definition is inclusive, the full dollar amount of any Roth conversion flows directly into that figure.

A $100,000 conversion of a pre-tax rollover IRA balance adds $100,000 to AGI on Form 1040. It is reported through Form 1099-R with distribution code 2 (if under age 59½) or code 7 (at or after age 59½). The conversion side is reported on IRS Form 8606. The receiving-side basis is tracked on IRS Form 5498 by the custodian.

The two-year offset is foundational. A household whose first Medicare-enrolled spouse turns 65 in February 2028 sees Part B and Part D premiums set by the 2026 federal return MAGI. A household whose first enrollee turns 65 in August 2030 sees premiums set by the 2028 MAGI.

The lookback applies independently to each spouse based on their own Medicare enrollment date. For a couple where one spouse enrolls in 2028 and the other in 2030, the 2026 MAGI prices the older spouse’s premium tier and the 2028 MAGI prices the younger spouse’s premium tier.

Both spouses can sit in different tiers depending on the joint MAGI in each of the two relevant lookback years.

Worth knowing: the IRMAA cliff is asymmetric. A household that has already crossed Tier 1 has zero incremental IRMAA cost on further conversions until the Tier 2 boundary. The marginal IRMAA cost of conversion dollars swings between zero (inside a tier) and the entire tier increment (at the boundary), unlike federal income tax marginal rates which are smooth.

For households whose baseline MAGI already sits above Tier 1, the planning question becomes which boundary is next and how much room remains inside the current tier.

Conversion sizing for a retired corporate executive in Florida

Florida residency removes one variable from the conversion arithmetic. The state has no personal income tax, so a Roth conversion is taxed only at the federal marginal rate and any IRMAA cliff that the conversion triggers. For a retired executive household with a $1.5 million rollover IRA balance considering a multi-year conversion ladder, the calendar is the planning lever.

The objective is to fill each year’s room up to the next IRMAA boundary, year over year, until the rollover balance is converted. The household then reaches age 73 and RMDs begin under IRC §401(a)(9) as amended by the SECURE Act 2.0.

Consider a household with a $90,000 corporate pension paid as a single-life or joint-and-survivor annuity under IRC §401(a)(11). Add $35,000 of taxable interest and dividends from a post-NUA brokerage account, and zero W-2 income. The baseline MAGI projection is $125,000. Against a 2025 MFJ Tier 1 cliff at $212,000, the household has $87,000 of room.

A $85,000 conversion costs federal income tax at the marginal rate (likely the 24% bracket given current TCJA bracket geometry, plus the 32% bracket on the top portion) and zero IRMAA. An $88,000 conversion costs the same federal tax plus $2,092 of per-couple IRMAA exposure for the at-65 premium year.

The arithmetic is asymmetric: $3,000 of incremental conversion triggers a fixed $2,092 cost. The conservative target leaves a 5% to 10% buffer below the boundary for year-end taxable items the household cannot perfectly project.

Multi-year ladder geometry then matters more than the single-year conversion size. Five consecutive years of $85,000 conversions at Tier 1 ceiling produce $425,000 of converted Roth balance with zero IRMAA exposure.

The same $425,000 executed as one $425,000 conversion in a single calendar year lands the household at the Tier 4 to Tier 5 boundary and produces $11,578 or more of single-year IRMAA cost.

The ladder structure exists because the cliff is annual; spreading conversions across calendar years converts the cliff into a series of smaller cliffs the household can size to.

Coordinating conversions with NUA, deferred compensation, and pension cashflow

Corporate executive households often carry employer stock with embedded Net Unrealized Appreciation under IRC §402(e)(4). The NUA election allows the cost basis of employer stock distributed from a qualified plan to be taxed as ordinary income at distribution. The appreciation above basis is taxed at long-term capital gain rates only when the stock is sold.

The mechanics interact with IRMAA in two ways. First, the cost-basis portion of the NUA distribution lands in AGI as ordinary income in the distribution year, which counts toward MAGI under §1395r(i)(4). Second, any subsequent sale of the employer stock realizes long-term capital gain in the year of sale, which also counts in MAGI.

Consider a household that completed an NUA distribution at age 60 or 61. Separating from service at or after age 55 satisfies the §402(e)(4) lump-sum requirement, so the cost-basis recognition lands in AGI that calendar year. If the NUA distribution year is also a Roth conversion year, the two events compound in MAGI.

The defensible sequence is to complete the NUA cost-basis recognition in one calendar year, then begin the Roth conversion ladder in the following year. The two ordinary-income events do not need to stack into the same MAGI computation.

Deferred compensation under IRC §409A follows the distribution election made at deferral. Many executive deferred-compensation plans pay out over a fixed schedule starting at separation or at a specified age, with the schedule locked under §409A’s anti-acceleration rules. The household generally cannot accelerate, defer, or reshape the §409A distribution stream to avoid an IRMAA cliff in a particular year.

The schedule is given. The Roth conversion sizing accommodates the schedule, not the other way around. A household projecting $80,000 of §409A income in 2026 and 2027, falling to $0 in 2028 and forward, would size the largest conversion blocks in 2028 onward when the §409A overhang has cleared.

The procedural sequence for sizing 2026 conversions against the lookback

The sequence executed cleanly by a retired executive household sizing a 2026 conversion against the two-year Medicare lookback has four steps. The first three are reversible at any point before the calendar year closes (no taxable event has occurred). The fourth is irreversible once the trustee-to-trustee transfer settles.

Step 1. Inventory baseline MAGI for the 2026 lookback year. Pull projected pension income (the federal-taxable portion), §409A distributions on the locked payout schedule, and any RSU vesting events not yet recognized. Also include taxable interest and dividends from post-NUA brokerage balances, capital gains realized year-to-date, and required tax-exempt interest under §1395r(i)(4).

Add any Social Security benefits the household has elected to start (rare in the age-60 to age-65 window for high earners). The resulting figure is the conversion-free MAGI projection for the 2026 calendar year.

Step 2. Pull the 2026 CMS bracket schedule and compute the room to each cliff. The October 2025 CMS fact sheet at cms.gov/newsroom is the source document. Subtract the Step 1 baseline from each tier boundary to compute the room available at each level.

A household projected at $145,000 conversion-free MAGI for 2026 has approximately $67,000 of room to the Tier 1 cliff, then progressively wider rooms to higher tiers. The arithmetic gives the household a menu of conversion sizes, each with a known IRMAA cost.

Step 3. Pick the conversion-size target inside the chosen tier. The conservative discipline is to leave a 5% to 10% buffer below the boundary in case year-end items (mutual-fund capital-gain distributions, late 1099 corrections, unexpected non-recurring income) push baseline MAGI higher than projected. A $65,000 conversion against $67,000 of headroom is acceptable; a $63,000 conversion is safer.

For households deliberately stacking into a higher tier, the calculus reverses: the household accepts the next-tier IRMAA cost as a known expense and sizes the conversion against the next-next-tier boundary, leaving the same conservative buffer.

Step 4. Execute the conversion and document the destination. The conversion is a trustee-to-trustee transaction from the source traditional IRA into the destination Roth IRA, reported on Form 1099-R by the source custodian and on Form 5498 by the destination custodian. The taxable amount is reported on Form 8606 with the household’s 1040.

If the destination Roth is a self-directed structure holding IRS-approved metals under §408(m), the destination custodian, depository, and dealer are named at this step. Screen the destination dealer against the 2026 OPRS list before any metals invoice is signed.

Dealer choice materially affects markup, depository fee, and buy-back posture, which are separate from the IRMAA question but compound the long-term cost of an unfavorable selection.

Common errors when stacking conversions against the 2026 cliff

One widespread mistake is treating IRMAA as a permanent annual burden rather than a time-limited consequence. The premium adjustment is tied to one specific calendar year of MAGI, not a rolling average. A $40,000 over-conversion in 2026 triggers elevated Medicare premiums in 2028 only, then expires.

A repeated over-conversion in 2026, 2027, and 2028 produces three years of elevated premiums in 2028, 2029, and 2030. The fix in practice is to spread the ladder across years that already have low projected MAGI, rather than stacking large conversions into a single high-MAGI year.

The second error is forgetting that tax-exempt municipal-bond interest counts in the §1395r(i)(4) MAGI definition. Executive households often hold meaningful municipal-bond positions inside taxable brokerage accounts for federal-tax-efficiency reasons. A household with $90,000 of pension income plus $35,000 of municipal-bond interest has $125,000 of IRMAA MAGI even though only $90,000 appears on the AGI line. The Form 1040 line 2a figure is added back. The household’s effective conversion room is computed against the higher MAGI, not the lower AGI.

The third error is sizing the conversion against the wrong year. Households sometimes plan against the Medicare-enrollment year rather than the lookback year. A retiree turning 65 in 2028 should be planning the 2026 MAGI window, not the 2028 window. The two-year offset is foundational to §1395r(i) and is the single most common source of IRMAA planning errors at the household level.

The fourth error is failing to coordinate with the spouse’s IRMAA enrollment timeline. The MFJ bracket is computed once on the joint return; both Medicare-enrolled spouses pay the resulting IRMAA tier each month, on each premium component.

A $200 increase in MAGI can push a couple over the Tier 1 boundary. When that happens, a $2,092 combined per-couple annual premium addition kicks in. Each spouse pays the Tier 1 surcharge on their own Part B and Part D premium. The household-level impact is double the per-person figure. Any planning that ignores the second spouse’s enrollment timeline undercounts the marginal cost.

Another error involves converting into a destination IRA without confirming that the custodian’s reporting matches the basis side of the transaction. Form 8606 filed by the household and Form 5498 issued by the receiving custodian must both reflect the same clean Roth conversion.

Discrepancies among the source 1099-R, the household Form 8606, and the receiving Form 5498 reach the §1395r(i) MAGI calculation only indirectly via IRS-to-SSA data exchange, yet they appear in the IRS notice cycle directly. Reconciling all three documents within the same tax year, before the conversion calendar rolls forward, is the defensible practice.

This applies equally to standard Roth IRAs and to self-directed Roths holding metals.

SSA-44 life-changing events and what they actually cover

Beneficiaries facing a sharp income change have a formal appeal route. The Social Security Administration allows them to seek a reduction in the IRMAA-based premium adjustment by submitting Form SSA-44, the Medicare Income-Related Monthly Adjustment Amount Life-Changing Event form.

The form covers eight enumerated life-changing events under 42 CFR §418.1205. They are: marriage, divorce or annulment, death of a spouse, work stoppage, work reduction, loss of income-producing property due to disaster, loss of pension income, and employer settlement payment. None of these covers a Roth conversion, by design. Voluntary tax-planning conversions are explicitly outside the SSA-44 framework.

For a retired corporate executive household, the most commonly applicable SSA-44 event is the work-stoppage category.

A household whose 2026 MAGI included a final year of W-2 income (say, a March 2026 separation from service) and whose 2028 income has since fallen significantly can file SSA-44. That form asks SSA to use the more recent, lower-income tax year for the premium computation.

The form requires documentation of the work-stoppage event and a projected income statement for the current year. SSA reviews the filing under §418.1205 and either approves the redetermination or maintains the standard two-year lookback.

The practical implication for conversion planning is that SSA-44 is not a retroactive correction for an over-conversion. The form is meaningful only when the lookback-year MAGI was elevated by a life event whose income effect has since reversed (work stoppage being the typical example for late-career executives). A household that voluntarily converted $200,000 to Roth in 2026 and is otherwise unchanged has no SSA-44 path. The conversion year’s IRMAA cost is locked.

How QCD coordination at age 70½ overlaps the conversion calendar

For households at or approaching age 70½, the Qualified Charitable Distribution at IRC §408(d)(8) becomes a parallel planning tool. A QCD is a direct trustee-to-charity transfer from a traditional IRA, up to the statutory cap (annually inflation-adjusted), that satisfies any RMD obligation for that year and is excluded from AGI. Excluded from AGI means excluded from MAGI under §1395r(i)(4).

For a household whose RMD year overlaps the conversion calendar, a QCD removes RMD-driven MAGI exposure without triggering income tax. This effectively widens the room available for a Roth conversion in the same year, by the QCD amount.

The arithmetic is straightforward. A household with a $30,000 RMD obligation in 2026, projected baseline MAGI of $145,000 absent any conversion, and a Tier 1 cliff at $212,000 has $67,000 of room. If the household redirects the entire $30,000 RMD as a QCD to a qualified §170(c) charity, the RMD obligation is satisfied without adding $30,000 to MAGI.

The conversion room then increases from $67,000 to roughly $97,000 (the original $67,000 plus the $30,000 of MAGI that the RMD would have added). For households with charitable intent and a planned RMD that would otherwise crowd out Roth conversion room, the QCD route compounds.

The OPRS coverage of the QCD mechanics for self-directed metals IRAs is in the QCD from a gold IRA at age 70½ guide.

Where conversion sizing meets estate planning at $1 to $3 million

The SECURE Act of 2019 and SECURE Act 2.0 amendments at IRC §401(a)(9)(H) require most non-spouse beneficiaries of inherited IRAs to fully distribute the inherited balance within 10 years of the original owner’s death. The 10-year rule applies to both traditional IRAs and Roth IRAs, but the tax treatment of the distributions differs by account type.

A non-spouse beneficiary inheriting a $1.5 million traditional IRA distributes $1.5 million of ordinary income across ten years, on top of the beneficiary’s own MAGI. A non-spouse beneficiary inheriting a $1.5 million Roth IRA distributes $1.5 million of tax-free distributions, with no MAGI impact and no IRMAA exposure for the beneficiary.

The cross-generational arithmetic favors a fully or partially converted Roth balance when the beneficiary’s own income trajectory is high.

Here is what that means for your heirs. An adult child inheriting at age 50, with their own MAGI already in the IRMAA-exposed range, faces a stark choice. On one side: a 10-year forced distribution of pre-tax dollars compounded with their own income, pushing them through multiple IRMAA tiers. On the other: a 10-year forced distribution of post-tax Roth dollars, with no MAGI impact and no IRMAA exposure.

For households planning estate transitions to high-earner adult children, the conversion calendar is partly a wealth-transfer strategy. The parent absorbs the conversion tax during years when their bracket is lower than the child’s projected future bracket. The child then receives a Roth balance that distributes without further tax friction. This keeps the inherited account clean for the next generation.

Our view: the 2026 calendar year is one of the most consequential planning windows in a retired executive household’s late-career sequence. The IRMAA cliff is not the only consideration.

Several factors combine in this window. The federal marginal rate depends on whether TCJA brackets expire after 2025 absent congressional action; the post-2025 schedule is the one referenced by IRC §1 as adjusted. The projected post-RMD bracket, the §409A distribution overhang, the NUA recognition timing, the QCD redirection at 70½, and the asset-location logic all combine.

But IRMAA is the consideration most often missed, because the cost shows up two years later through Medicare premium withholdings on a different form processed by a different agency. A household that runs the four-step sequence in advance avoids the surprise.

The conversion sizing decision is reversible up to December 31 of the conversion year. The destination decision (which custodian, which dealer if the Roth is funding a self-directed metals structure) is reversible up to the moment the metals invoice is signed.

Before any conversion is executed and any metals are purchased, run the four-step sequence. Pull the October 2025 CMS IRMAA bracket release. Then screen any destination dealer against the 2026 OPRS list of gold IRA operators we do not recommend.

For households where the destination is a standard Roth IRA holding equities or fixed income, the dealer-screening step does not apply; the IRMAA sizing step still does.

More on OPRS

For households running the Roth conversion ladder during the pre-RMD window, the Roth conversion ladder pre-RMD framework covers the multi-year arithmetic in greater detail. For households approaching the QCD-eligibility age of 70½ with a self-directed metals IRA, the QCD mechanics for gold IRA guide covers the §408(d)(8) procedural sequence.

For households evaluating the estate-transition arithmetic of inherited IRA balances at $1 to $3 million across multiple beneficiaries, the estate planning at $3 million framework covers the SECURE Act 10-year rule sequencing. Before any metals invoice is signed, the 2026 OPRS list of gold IRA dealers we warn readers against is the dealer-screening reference.

Sources cited

1. 42 USC §1395r: Amount of Medicare premiums, including §1395r(i) Income-Related Monthly Adjustment Amount and the two-year MAGI lookback rule
2. 42 CFR §418.1010: Initial IRMAA determination by SSA
3. 42 CFR §418.1115: IRMAA tier thresholds and tier-determination methodology
4. 42 CFR §418.1205: Life-changing event categories qualifying for an SSA-44 redetermination
5. SSA POMS HI 01101.010: IRMAA Program Overview
6. SSA Form SSA-44: Medicare Income-Related Monthly Adjustment Amount Life-Changing Event
7. IRC §408A: Roth IRAs (conversions, ordering rules, qualified distributions, five-year clocks)
8. IRC §408: Individual Retirement Accounts (including §408(m) IRS-approved precious metals and §408(d)(8) QCD)
9. IRC §402(e)(4): Net Unrealized Appreciation rules for employer securities
10. IRC §409A: Inclusion in gross income of deferred compensation under nonqualified deferred compensation plans
11. IRC §401(a)(9): Required Minimum Distribution rules (including §401(a)(9)(H) SECURE Act 10-year rule for non-spouse beneficiaries)
12. IRS Form 8606: Nondeductible IRAs (Roth conversion basis tracking)
13. IRS Form 5498: IRA Contribution Information (custodian-side reporting of conversions)
14. IRS Publication 590-A: Contributions to Individual Retirement Arrangements
15. IRS Publication 590-B: Distributions from Individual Retirement Arrangements
16. CMS Fact Sheet: 2025 Medicare Parts A and B Premiums and Deductibles (IRMAA bracket schedule)