IRMAA · Mesa County · Colorado's Western Slope
Do IRA or 401(k) Withdrawals Count Toward IRMAA in 2026?
The withdrawal counts. The rollover does not. The Roth usually does not. Here is how the IRS sorts the money that leaves a retirement account, which lines of your 1040 Social Security actually reads, and what a $40,000 IRA withdrawal in Mesa County costs two years later.
The bottom line
- Yes: the taxable part of a traditional IRA or 401(k) withdrawal counts toward IRMAA, dollar for dollar. It is ordinary income on line 4b or 5b of your Form 1040, and Social Security reads your adjusted gross income plus tax-exempt interest (20 CFR § 418.1010). For 2026 the surcharge starts above $109,000 single / $218,000 joint on your 2024 return; for 2027 the first line is $111,000 / $222,000 on your 2025 return.
- No: a rollover does not count, even though the Form 1099-R can show a six- or seven-figure number in box 1. The IRS says a rollover "isn't taxable ... but it is reportable" (Topic 413). The exception is anything you fail to redeposit within 60 days, including the 20% an employer plan must withhold.
- No: qualified Roth withdrawals do not count. A qualified distribution from a Roth IRA or Roth 401(k) "isn't included in your gross income" (Pub. 575), so it never reaches MAGI. The conversion that funded it counted in the conversion year.
- A withdrawal is not appealable. Social Security's list of life-changing events covers stopping work, marriage, divorce, death and a few others (§ 418.1205); choosing to take money out is not on it, so a one-year surcharge from a withdrawal simply has to be paid.
- Worked example below: a Mesa County couple at $190,000 MAGI who pull $40,000 from an IRA in 2026 cross the first joint line and pay $2,296.80 more for Medicare in 2028. Split across two Decembers, they pay nothing extra.
The question arrives in two versions. The first is from someone who is 66, retired, and wants to pull $40,000 out of an IRA for a truck, a roof or a daughter's down payment, and has heard that it might raise their Medicare premium. The second is from someone who just retired, rolled a 401(k) worth several hundred thousand dollars into an IRA, got a 1099-R in January with that whole number printed in box 1, and is now afraid their Part B premium is about to triple. The first person is right to ask. The second person can relax, as long as the rollover was done correctly. This article is the sorting rule for both, with the IRS language that backs each line, and the 2026 table that turns the answer into dollars.
What Social Security actually reads
Medicare's income-related monthly adjustment amount, IRMAA, is not based on "income" in the everyday sense. The regulation defines it precisely: "Modified adjusted gross income is your adjusted gross income as defined by the Internal Revenue Code, plus the following forms of tax-exempt income: (i) Tax-exempt interest income; (ii) Income from United States savings bonds used to pay higher education tuition and fees; (iii) Foreign earned income; (iv) Income derived from sources within Guam, American Samoa, or the Northern Mariana Islands; and (v) Income from sources within Puerto Rico" (20 CFR § 418.1010(b)(6)).
Read that list again, because it answers the question. Retirement-account withdrawals are not one of the five add-backs. They count toward IRMAA only to the extent they are already inside adjusted gross income, which means the only thing that matters is what your tax return puts on line 4b (IRA distributions, taxable amount) and line 5b (pensions and annuities, taxable amount). Line 4a and line 5a, the gross amounts, are not read at all. So the whole exercise is figuring out which retirement-account transactions produce a number on 4b or 5b, and which produce a number only on 4a or 5a. The table below does that for the ten moves we see most often in Grand Junction.
Ten things that come out of a retirement account, sorted
| What you did | Counts toward IRMAA? | Where it lands | Why |
|---|---|---|---|
| Withdrawal from a traditional IRA, 401(k), 403(b) or 457(b) | Yes, the taxable amount | 1040 line 4b (IRA) or 5b (plan) | Pub. 590-B: with no basis, "any distributions are fully taxable when received" — ordinary income, inside AGI. |
| Required minimum distribution | Yes | Line 4b / 5b | An RMD is a taxable withdrawal that cannot be rolled over (Topic 413). |
| Roth conversion | Yes, the converted amount | Line 4b, via Form 8606 | The amount moved is income in the conversion year — covered in our Roth-conversion post. |
| Direct rollover, 401(k) → IRA (1099-R code G) | No | Line 5a only; 5b is $0 | Topic 413: a rollover "isn't taxable ... but it is reportable." Box 2a of the 1099-R is zero. |
| 60-day rollover you completed in full | No | Line 4a / 5a only | Same rule — but the 20% the plan withheld counts unless you replaced it from savings when you rolled over. |
| The part of a 60-day rollover you did NOT redeposit | Yes | Line 4b / 5b | Topic 413: "You must include the taxable amount of a distribution that you don't roll over in income." |
| Qualified Roth IRA or Roth 401(k) withdrawal | No | Line 4a / 5a only | Pub. 575: a qualified designated-Roth distribution "isn't included in your gross income" (5 tax years + age 59½). |
| Return of after-tax (nondeductible) contributions | No, that slice | Form 8606 splits 4a from 4b | Pub. 590-B: only the basis portion is tax free, pro-rated across all your traditional IRAs. |
| Qualified charitable distribution, age 70½+ | No | Line 4a, "QCD" on 4c | Excluded from gross income entirely — covered in our RMD post. |
| Trustee-to-trustee transfer between two IRAs | No | Not a distribution | Money that never leaves the IRA wrapper is not reported as a withdrawal. |
Sources: IRS Pub. 590-B · IRS Pub. 575 · IRS Topic 413 · Form 1099-R instructions · 20 CFR § 418.1010. Line numbers are from Form 1040; the 1040-SR uses the same numbering. Roth conversions and qualified charitable distributions each have their own post, linked in the rows.
The withdrawal: why it counts in full
For most people the IRA or 401(k) was funded entirely with pre-tax money, and the IRS is direct about what that means on the way out: "If only deductible contributions were made to your traditional IRA (or IRAs, if you have more than one), you have no basis in your IRA. Because you have no basis in your IRA, any distributions are fully taxable when received," and "Distributions from traditional IRAs that you include in income are taxed as ordinary income" (Pub. 590-B). The reporting instruction follows: "Report fully taxable distributions, including early distributions, on Form 1040, 1040-SR, or 1040-NR, line 4b." Employer-plan money works the same way on line 5b. There is no capital-gains treatment, no exclusion, no averaging. The whole withdrawal is income in the year the check is cut, and the whole withdrawal is inside the MAGI Social Security reads two years later.
Two refinements. If you ever made nondeductible contributions to a traditional IRA, you have basis, and "only the part of the distribution that represents nondeductible contributions and rolled over after-tax amounts (your cost basis) is tax free." Form 8606 does the pro-rating, across every traditional IRA you own, and only the taxable remainder reaches 4b. And if you are under 59½, the IRS adds its own penalty on top of the income tax: "Individuals must pay an additional 10% early withdrawal tax unless an exception applies" (IRS). The penalty is a tax, not income, so it does not itself raise MAGI; the withdrawal that triggered it does.
The rollover: why the big 1099-R does not count
This is the one that sends people to our office in February. You retired from the hospital, the county, the college or an energy company; you moved the 401(k) or 403(b) to an IRA; and the plan mailed a Form 1099-R with the entire balance in box 1. The IRS rule: "A rollover occurs when you withdraw cash or other assets from one eligible retirement plan and contribute all or part of it, within 60 days, to another eligible retirement plan. This rollover transaction isn't taxable (unless the rollover is to a Roth IRA or a designated Roth account from another type of plan or account), but it is reportable on your federal tax return" (Topic 413).
"Reportable" is why the 1099-R exists; "isn't taxable" is why it does not matter for Medicare. For a direct rollover the plan is told to "enter -0- (zero) in box 2a" and to use distribution code G (1099-R instructions). On your return the gross amount goes on line 5a, the taxable amount on 5b is zero, and Social Security sees nothing. A trustee-to-trustee transfer between two IRAs is even quieter: it is not a distribution at all.
The rollover rule has one sharp edge, and it cuts people who take the check themselves. "Any taxable eligible rollover distribution paid to you from an employer-sponsored retirement plan is subject to mandatory income tax withholding (generally at a rate of 20%)," and "You must include the taxable amount of a distribution that you don't roll over in income in the year of the distribution" (Topic 413). So if a $300,000 plan balance is paid to you, the plan sends $60,000 to the IRS and $240,000 to you. Unless you find $60,000 elsewhere and deposit the full $300,000 into the IRA "by the 60th day following the day on which you receive the distribution" (Pub. 575), the $60,000 that was withheld is a taxable distribution, it lands on line 5b, and it counts toward IRMAA. The fix is procedural: ask for a direct rollover, payable to the new custodian, and the 20% never comes out.
The Roth: why qualified withdrawals do not count
A Roth IRA withdrawal is qualified when "it is made after the 5-year period beginning with the first tax year for which a contribution was made to a Roth IRA set up for your benefit" and is "made on or after the date you reach age 59½," or on disability or death (Pub. 590-B). For a Roth 401(k), "if you receive a qualified distribution from a designated Roth account, the distribution isn't included in your gross income. This applies to both your cost in the account and income earned on that account" (Pub. 575). Not in gross income means not in adjusted gross income means not in MAGI. A retired couple drawing $40,000 a year from a Roth has, for Medicare purposes, drawn nothing.
The honest footnote is that the money got into the Roth one of two ways. If it went in as contributions from a paycheck, it was taxed then and is done. If it went in by conversion, the converted amount was ordinary income in the conversion year and counted toward IRMAA for the premium year two years later. The Roth does not erase the IRMAA cost of a withdrawal; it lets you choose the year you pay it and then stop paying it. For a household that expects to be above $218,000 every year once required minimum distributions begin at 73, that trade can be worth making in the lower-income years between retirement and 73. It is a tax-planning decision, and your tax advisor should run it, not us.
The 2026 table the withdrawal lands on
Here is the full 2026 table from CMS's November 14, 2025 fact sheet, read against 2024 returns. The 2027 version applies the same shape to 2025 returns, with the first line already published at $111,000 / $222,000 (Medicare & You 2027, p. 86) and the rest due in November; we track that here.
| 2024 MAGI, single | 2024 MAGI, joint | Part B surcharge | Total Part B | Part D surcharge |
|---|---|---|---|---|
| $109,000 or less | $218,000 or less | $0.00 | $202.90 | $0.00 |
| $109,001 – $137,000 | $218,001 – $274,000 | $81.20 | $284.10 | $14.50 |
| $137,001 – $171,000 | $274,001 – $342,000 | $202.90 | $405.80 | $37.50 |
| $171,001 – $205,000 | $342,001 – $410,000 | $324.60 | $527.50 | $60.40 |
| $205,001 – $499,999 | $410,001 – $749,999 | $446.30 | $649.20 | $83.30 |
| $500,000 and up | $750,000 and up | $487.00 | $689.90 | $91.00 |
Source: CMS — 2026 Medicare Parts A & B Premiums and Deductibles / 2026 Part D IRMAA (Nov 14, 2025). Per person, per month. The Part D surcharge is paid to Medicare, not to the plan, and applies to Advantage plans with drug coverage too.
A Mesa County couple, one withdrawal, two years later
Take a retired couple on the Redlands filing jointly: a pension, two Social Security checks, some dividends and interest, for a base 2026 MAGI of $190,000. (That number is an assumption chosen to sit near the first joint line; everything after it is arithmetic on the table above.) In 2026 they take $40,000 out of a traditional IRA to replace a truck.
| Scenario | 2026 MAGI | Tier | Part B, both, 2028 | Part D surcharge, both, 2028 | Extra for the year |
|---|---|---|---|---|---|
| No withdrawal (truck from savings or a Roth) | $190,000 | Standard | $202.90 × 2 | $0 | $0 |
| $40,000 from the IRA in 2026 | $230,000 | Second ($218,000 line crossed) | $284.10 × 2 | $14.50 × 2 | $2,296.80 ($1,948.80 B + $348.00 D) |
| $20,000 in Dec 2026 + $20,000 in Jan 2027 | $210,000 / $210,000 | Standard both years | $202.90 × 2 | $0 | $0 |
Arithmetic on the CMS 2026 table; the 2028 premium will use the 2028 table, which is not published, so the dollar figures are the 2026 surcharges used as a stand-in. Part D surcharges assume both spouses have drug coverage.
The same $40,000, the same truck, and the difference between row two and row three is $2,296.80 for one premium year. The couple had $28,000 of room under the $218,000 line; a withdrawal sized to the room, with the rest in January, never crosses it. Notice too what the rule does not care about: withholding. Having the custodian hold back 20% for taxes feels like settling up, and it does settle the income tax, but withholding does not reduce the taxable amount on line 4b by a dollar. The gross withdrawal is what counts.
Notice the second thing the rule does not care about: why you took the money. Social Security's list of life-changing events, the ones that let you file Form SSA-44 and have a lower current-year income used instead, is specific: your spouse dies, you marry, your marriage ends, "you or your spouse stop working or reduce the hours you work," you lose income-producing property through no fault of your own, an employer pension plan is terminated or reorganized, or you receive an employer settlement (20 CFR § 418.1205). A withdrawal you chose to take is not on it. If the couple above had retired in 2026, the retirement would be appealable; the truck would not, and the surcharge for 2028 would stand. The appeal post walks through the form.
What this looks like in Grand Junction
Sources: CMS 2026 fact sheet · CMS Medicare Monthly Enrollment · CDC PLACES, 2023 — via the Medicare On Main Data Desk. The county estimate is 8% of 41,709; Mesa County's income mix may differ from the national one.
Mesa County retires a particular kind of household: a career at St. Mary's, the college, the county or an energy company, a pension or a well-funded 403(b), and a spouse with a rollover IRA of their own. Those households sit closer to the $218,000 line than they guess, and the years between retirement and 73 are when the IRA is the obvious place to reach for a large one-time expense. It is also, per CDC PLACES, a county where 26.6% of adults live with high blood pressure and 8.1% with diabetes, so the Part D surcharge is not theoretical; it rides on a drug plan that is getting used. If there is a Roth, a taxable brokerage account or plain savings to draw from instead, the IRMAA math belongs in the decision about which account pays for the truck. If there is not, the calendar is the lever: a withdrawal split across December and January is two smaller numbers on two returns.
Planning a large IRA withdrawal this year?
Bring your 2025 return and the amount you have in mind. We'll show you where it lands on the 2026 and 2027 lines, what it does to both surcharges two years out, and whether your current plan is still the right fit, free and no pressure at our Grand Junction office or by phone. For which account to draw from, bring your tax advisor.
Talk it through with Brian →What I would do before taking the money out
- Find this year's MAGI so far. Adjusted gross income plus tax-exempt interest, projected to December 31. Compare it to $109,000 single / $218,000 joint. The gap is the room you have.
- Size the withdrawal to the room, or split it across two Decembers. Two years' worth of room is twice the room. January is only a few weeks away from December.
- Ask whether a Roth or a taxable account can pay instead. A qualified Roth withdrawal adds nothing to MAGI; a brokerage sale adds only the gain, which has its own rules.
- Moving a 401(k)? Use a direct rollover. Payable to the new custodian, code G, zero in box 2a. Never take the check yourself if you can avoid it; the 20% withholding becomes income unless you replace it within 60 days.
- At 73 or older, remember the withdrawal is partly mandatory. The required minimum distribution counts and cannot be rolled over; the RMD post covers the April 1 two-distribution trap and qualified charitable distributions.
- Retired this year too? That part is appealable. File SSA-44 for the stop-work event with your estimate of this year's lower income (SSA); the withdrawal itself is not, so keep the estimate honest and include it.
How we know all this: the Medicare On Main Data Desk frames every article with public data — here, the Social Security regulations defining modified adjusted gross income and life-changing events, IRS Publications 590-B and 575, Tax Topic 413 and the Form 1099-R instructions, CMS's November 14, 2025 fact sheet on 2026 premiums and IRMAA, the 2027 Medicare & You handbook, CMS county enrollment data and CDC PLACES. The worked example is arithmetic on published tables with stated assumptions. IRMAA is set by Social Security from your tax return, not by any plan or agent, and nothing here is tax advice; confirm your figures with SSA, Medicare.gov or a licensed agent, and account-selection and conversion questions with your tax advisor. We take no payment from any carrier to feature a plan.
Frequently asked questions
Do 401(k) withdrawals count as income for Medicare?
Yes. The taxable part of any withdrawal from a traditional 401(k), 403(b), 457(b) or IRA is ordinary income on your Form 1040, and Social Security sets your Medicare premium from that return's adjusted gross income plus tax-exempt interest (20 CFR § 418.1010). For 2026 the income-related surcharge begins above $109,000 for a single filer and $218,000 for a couple filing jointly, measured on your 2024 return. A withdrawal you take in 2026 shows up in the premium Social Security sets for 2028.
Do IRA withdrawals count as income for Medicare premiums?
Yes, the same way. IRS Publication 590-B says that if you made only deductible contributions to your traditional IRA, "any distributions are fully taxable when received," and taxable IRA income lands on line 4b of your return, inside adjusted gross income. If some of your contributions were nondeductible, Form 8606 splits each withdrawal into a tax-free return of basis and a taxable remainder, and only the taxable remainder reaches your Medicare premium.
Does a 401(k) rollover count as income for IRMAA?
No, as long as it is a real rollover. The IRS says a rollover "isn't taxable ... but it is reportable": a direct rollover from a 401(k) to an IRA arrives on a Form 1099-R with code G and a zero in box 2a, goes on line 5a of your 1040, and adds nothing to line 5b or to your Medicare premium. The trap is the indirect, 60-day version: the plan must withhold 20%, and any part you do not redeposit within 60 days, including that withheld 20% unless you replace it from other savings, is a taxable distribution that does count.
Do Roth IRA withdrawals count toward IRMAA?
Qualified ones do not. A Roth IRA withdrawal is qualified when it is made after the five-year period that starts with your first Roth contribution and after you reach 59½ (or on disability or death), and a qualified distribution from a Roth 401(k) "isn't included in your gross income," per IRS Publication 575. Money that never enters gross income never enters the modified adjusted gross income Social Security uses. The conversion that put the money into the Roth did count, in the year you converted.
Will IRA withdrawals affect my Medicare premiums if I take them before 65?
They can. Social Security looks at your tax return from two years before each premium year, so withdrawals at 63 and 64 are what set your premium at 65 and 66. That is the trap for people who retire early and live on their IRA before Social Security starts. If the withdrawals come before age 59½ they also carry the IRS's additional 10% early-distribution tax unless an exception applies. And because a withdrawal you chose to take is not a life-changing event under 20 CFR § 418.1205, the surcharge it causes cannot be appealed; only the drop in income from retiring itself can.
Does Medicare On Main charge for help with IRMAA questions?
No. Brian Penner is an independent licensed Medicare advisor with 22+ years of experience, paid by the carriers, not by you, and IRMAA is set by Social Security from your tax return, not by any plan. We'll show you where your income lands on the 2026 table and what a plan change does and does not change; for the question of which account to draw from, bring your tax advisor. Our Grand Junction office is at 627 24 1/2 Rd Ste H; call (970) 644-6954. We do not offer every plan available in your area.
Sources
- 20 CFR § 418.1010 — definitions; (b)(6) modified adjusted gross income (Cornell LII) — AGI plus five add-backs; withdrawals are not an add-back.
- 20 CFR § 418.1205 — what is a major life-changing event? (Cornell LII) — a withdrawal you choose is not a life-changing event.
- 20 CFR § 418.1135 — which year's tax return SSA uses (two years before).
- IRS Publication 590-B — Distributions from Individual Retirement Arrangements (IRAs) — "any distributions are fully taxable when received"; line 4b; Form 8606; qualified Roth distributions.
- IRS Publication 575 — Pension and Annuity Income (rollovers; designated Roth accounts) — "by the 60th day"; designated Roth qualified distribution "isn't included in your gross income."
- IRS Tax Topic 413 — Rollovers from retirement plans — "isn't taxable ... but it is reportable"; mandatory 20% withholding; RMDs can't be rolled over.
- IRS Instructions for Forms 1099-R and 5498 — box 2a, box 2b, code G — zero in box 2a for a direct rollover; code G.
- IRS — Retirement topics: exceptions to tax on early distributions (the age 59½ rule).
- CMS — 2026 Medicare Parts A & B Premiums and Deductibles / 2026 Part D IRMAA (Nov 14, 2025) — the full 2026 table; "roughly 8%".
- Medicare & You 2027 handbook (Medicare.gov, PDF) — p. 86, the 2027 first IRMAA threshold.
- SSA — Medicare premiums: rules for higher-income beneficiaries (Form SSA-44 and life-changing events).
- CMS Medicare Monthly Enrollment (data.cms.gov) — Mesa County, CO, June 2026 — 41,709 people with Medicare.
- CDC PLACES: Local Data for Better Health, County 2023 — Mesa County chronic-condition prevalence.
- Medicare Plan Compare (Medicare.gov) — every plan available in your county.