When an atom is driven by a laser field with a photon energy that is nearly resonant with an atomic transition, it can undergo periodic population transfers between the ground and excited state, known as Rabi oscillations [1], [2]. The aim of this work is to study photoionization from atoms for parameters accessible to a free-electron laser (FEL) [3]. Using time dependent perturbation theory to model photoionization from a Rabi oscillating atom, we have shown that in addition to the expected pathway of ionization from the excited state, non-resonant two-photon ionization will have a comparable amplitude at intensities on the order of 10 13 W/cm 2 [3].