In this Beyond the Basics webinar presented by the Center on Budget and Policy Priorities on October 7, 2021, Tara Straw, Director of Health Insurance and Marketplace Policy, provides an in-depth overview of the HealthCare.gov auto-renewal process for 2022 coverage, including the process for plan enrollment and redetermination of premium tax credit eligibility.

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Active Re-enrollment

• Importance of Returning to the Marketplace

Redetermination of APTC by HealthCare.gov

• Redetermination Process for HealthCare.gov
• Notices About Redetermination Process
• Who is Eligible for Redetermination of APTC
• Who is Not Eligible for Redetermination of APTC
• Who is Not Eligible for Auto-Renewal
• How APTC and CSR are Redetermined

Auto-Enrollment for 2022 Plans in HealthCare.gov

• Three Possible Auto-Enrollment Options
• SEP When Auto-Enrolled in New Plan
• Notices About Renewal Process
• Terminating Coverage
• Tips for Assisters

Additional Resources

Key Facts About Auto-Renewal of Premium Tax Credits

Key Facts About Past Due Premiums

In this Health Reform: Beyond the Basics webinar presented on October 8, 2020, Tara Straw, Senior Policy Analyst, provides an overview of the HealthCare.gov auto-renewal process for 2021 coverage, including the process for plan enrollment and redetermination of premium tax credit eligibility.

↓ View Presentation Slides (PDF)

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Encourage Active Re-enrollment

• Why Should Consumers Choose Active Re-enrollment?

Redetermination of APTC

• Redetermination Process for HealthCare.gov
• Notices About Redetermination Process
• Eligibility for Redetermination of APTC
• Failure to Reconcile
• Example

Auto-Enrollment for 2021 Plans

• Notices About Renewal Process
• Auto-Enrollment Process
• SEP When Auto-Enrolled in New Plan
• Examples
• Canceling 2021 Coverage
• Tips for Assisters

Additional Resources

Key Facts About Auto-Renewal of Premium Tax Credits

Key Facts About Past Due Premiums

Each open enrollment period, people receiving advance premium tax credits (APTC) to help them pay for health coverage have to renew their eligibility. The following questions and answers provide information about how the Federally-Facilitated Marketplace (FFM) will renew eligibility for APTC and will briefly explain how Healthcare.gov will assign people to health plans if they don’t come back to the marketplace to select a plan.

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Do enrollees have to return to the marketplace during open enrollment?

For most enrollees in states using HealthCare.gov, there is a process to auto-renew their eligibility for advance premium tax credits (APTC) and auto-enroll them in a health plan if they don’t return to the marketplace to update their financial information and pick a health plan.

Even though this process is available, it is highly recommended that all enrollees return to the marketplace to update their eligibility and plan selection, particularly in this upcoming open enrollment period when there will be significant changes to health plans in many states.

What happens if enrollees do not return to the marketplace to update their eligibility information and select a health plan?

Two actions will take place for enrollees who don’t return to the marketplace.

• Auto-Renewal of Eligibility for APTC. However, the marketplace will not be able to automatically redetermine eligibility for APTC for all enrollees.
• Auto-Enrollment. People will be automatically enrolled in their current plan if it is still available in the marketplace. If the plan isn’t available, HealthCare.gov will enroll people in a new plan that is as similar as possible to their current plan.

How will HealthCare.gov auto-renew eligibility for APTC?

For enrollees who do not return to the marketplace to update their information, the FFM will recalculate their APTC based on the most recent income information that the FFM has for them using updated benchmark plan premiums and poverty level thresholds.

There are some people, however, who will not have their APTC automatically renewed. They must return to Healthcare.gov and provide updated information to renew their APTC. The FFM will send notices to enrollees telling them whether they must return to Healthcare.gov to continue receiving the APTC.

How will HealthCare.gov determine whose APTC can be auto-renewed and whose can’t?

Before open enrollment, the FFM will check Internal Revenue Service (IRS) data and use information from enrollees’ tax returns to determine whether or not their APTC can be auto-renewed if they don’t come back to HealthCare.gov and update their information. The notices enrollees receive from the FFM will tell them whether they can be auto-renewed or whether they must return to HealthCare.gov.

Most people will be able to auto-renew their APTC. However, HealthCare.gov will notify a small number of enrollees that unless they return to the marketplace to update their information, HealthCare.gov will automatically enroll them into the same or similar plan, but will discontinue their APTC. These include people who fall into any of the following groups:

• Opt-Out Group. Enrollees are in the opt-out group if they did not authorize the FFM to access tax return information in order to redetermine their APTC eligibility. When consumers apply for APTC, HealthCare.gov asks them to give the FFM consent to obtain their tax data for five years. A small number of enrollees who did not provide this consent must return to HealthCare.gov and provide consent in order to continue receiving APTC.
• Failure to File or Reconcile Group. People in this group received APTC in 2019 but did not file a 2019 tax return or reconcile their 2019 APTC on the tax return. The ACA requires that people file a tax return for any year in which they receive APTC. When people file their return, they must reconcile the APTC amount they received against the final credit amount for which they are eligible. In general, the FFM will discontinue APTC for enrollees who did not file a tax return or who filed but did not reconcile the credit in the previous tax filing year. This means that for 2021, if a person received ATPC in 2019 and did not file a tax return to reconcile her APTC for that year, then the FFM will discontinue APTC for 2021.
• Above Income Group. People in this group have 2019 tax income that is above 500 percent of the poverty line. These are people whom the FFM has identified as being at highest risk of having 2021 income that would make them ineligible for APTC.
• Repeat Passive Group. This is a group of people who were automatically re-enrolled in marketplace coverage with APTC in both 2019 and 2020, did not return to the marketplace to update their eligibility in those years, and there is no IRS information on their income for those years.

Individuals who fall into any of these groups will receive a notice saying that unless they take action, they will not receive APTC in 2021 for one of the reasons outlined above. When the enrollee returns to HealthCare.gov, he or she will need to go through the entire application to provide information the FFM needs to redetermine their APTC eligibility for 2021.

When will people receive notices and what information will the notices contain?

Enrollees will receive two types of notices before open enrollment begins. The first will be a notice from their insurer, which will include:

• Information about whether enrollees can be auto-enrolled into the same or a similar plan for 2021, and if so, any key changes to benefits and cost-sharing between the 2020 and 2021 plans;
• Information about the 2021 plan’s premium, including, for people receiving APTC, an estimated APTC amount based on the prior year’s amount;
• Information about other health coverage options, including how to pick a different plan in the marketplace;
• Where the consumer can call with questions;
• An explanation of the requirement to report changes to the marketplace;
• For people receiving APTCs, an explanation of the APTC reconciliation process; and
• For people receiving cost-sharing reductions (CSRs) who are being auto-enrolled into a non-silver plan, an explanation that CSRs are only available if enrolled in a silver plan.

HealthCare.gov will send a separate notice containing the following standard information:

• Description of the annual redetermination and re-enrollment process;
• Reminder to report changes that might affect eligibility;
• Key dates, including the last day of open enrollment; and
• A description of how eligibility for the APTC and CSRs will be redetermined if enrollees don’t return to Healthcare.gov to update their information.

All enrollees will receive a notice with this information from the marketplace, but enrollees who fall into the opt out, failure to file or reconcile, above income, or repeat passive groups described above will receive additional information telling them they need to return to Healthcare.gov and update their eligibility in order to continue receiving the APTC in 2021.

What will people in the “failure to file or reconcile” group need to do to continue receiving APTC in 2021? 

People who did not file a 2019 tax return to reconcile the APTC they received in 2019 must do so and return to HealthCare.gov to update their eligibility during open enrollment. Since it will take time for the IRS to process new tax filings, the FFM will not be able to immediately verify whether enrollees have filed and will accept enrollees’ attestation that they filed a tax return and reconciled their 2019 APTC. The FFM will later verify this information with the IRS, and if the IRS cannot verify that a 2019 tax return was filed, APTC may be discontinued.

How will the FFM recalculate APTC amounts for people who don’t update their eligibility? 

For 2021, the FFM will recalculate the APTC by applying the updated federal poverty line (FPL) thresholds and benchmark premiums, and by using the most recent income information that is available to the FFM, adjusted to 2021. The FFM has three sources of income it can use to redetermine enrollees’ APTC eligibility, based on the following hierarchy:

• Projected 2020 income, adjusted to 2021. Enrollees who have projected 2020 income the FFM can use include people who returned to HealthCare.gov during the last open enrollment period to update their eligibility, newly applied for the APTC in 2020, or reported a change in income in 2020. If an enrollees’ projected 2020 income, adjusted to 2021, is below 100 percent FPL (except for certain non-citizens), the FFM will use enrollees’ 2019 tax return information.
• 2019 tax return income, adjusted to 2021. If the FFM doesn’t have projected 2020 income, it will use the enrollee’s income from his 2019 tax return. Enrollees who may be in this situation include those who received and reconciled a 2019 APTC, but who did not update their eligibility during the last open enrollment period. However, two exceptions apply. First, enrollees whose 2019 tax return income, when adjusted to 2021, goes over 400 percent FPL will not be able to auto-renew their APTC for 2021. Second, the FFM will use enrollees’ projected 2019 income for enrollees whose 2019 tax return income, when adjusted to 2021, is below the poverty line.
• Projected 2016 income, adjusted to 2018. If the FFM doesn’t have projected 2020 income or 2019 tax return income, it will use enrollees’ projected 2019 income to redetermine and recalculate the 2021 APTC.

If the FFM does not have projected 2019 or 2020 income, or 2019 tax return income — and the consumer was auto-enrolled in APTC in both 2019 and 2020 — the FFM will discontinue APTC for 2021.

How will HealthCare.gov adjust 2019 or 2020 income to 2021? 

Regardless of the income source the FFM uses, it will adjust for expected income growth from 2019 or 2020 to 2021. This adjustment is based on the percentage change in the federal poverty level for the enrollee’s applicable family size from the year for which annual household income information is used for redetermination to 2021. For example, if the FFM is using 2019 projected income, it will adjust that income to 2021 by applying the rate of growth in the FPL used to determine APTC eligibility in 2019 (which is the 2018 poverty thresholds) to the FPL used to determine eligibility in 2021 (which is the 2020 poverty thresholds). Table 1 lists the expected income growth from 2019 and 2020 to 2021 that the FFM will apply to enrollees’ household income, for families of one to four individuals.

To illustrate, suppose that a single person’s income on his 2019 tax return was $20,000, and this is the income information that the FFM has available to redetermine APTC eligibility in 2021. The percentage change in the poverty guidelines used to determine 2019 and 2021 APTC eligibility is 1.0510 ($12,760 divided by $12,140). The FFM would apply this growth rate to the enrollee’s 2019 income to get a projected 2021 income of $21,021.

Will State-Based Marketplaces use the same renewal process? 

The renewal process may be different in states that established their own marketplaces, unless the state uses the HealthCare.gov platform for enrollment. State-Based Marketplaces (SBMs) have three options for how to conduct renewals:

• Renewal process in original regulation. SBMs could use the process outlined in 45 C.F.R. §155.335(b) through (m) of the regulations, which require the marketplace to obtain updated information through electronic data sources and use that information to redetermine people’s APTC. SBMs would need to obtain updated income and family size information, provide notice to enrollees indicating the information that will be used to redetermine their eligibility, give them 30 days to respond and report any changes to the information contained in the notice. If enrollees don’t respond, the SBM redetermines eligibility using the information contained in the notice.
• Alternative procedure specified by HHS for the applicable benefit year. For each open enrollment period, HHS may specify an alternative process for conducting renewals that the FFM will use, and SBMs have the option of using the same process. HHS will typically announce this alternative process by issuing guidance in the spring preceding the open enrollment period. This Q&A describes the alternative process that the FFM will use to renew enrollees’ APTC for 2018.
• HHS-approved, state-designed alternative. SBMs can also use their own alternative procedures for conducting renewals, with approval from HHS. SBMs must show that the alternative procedure would facilitate continued enrollment in coverage for eligible enrollees, provide enrollees clear information about the process, and ensure that the alternative process would result in accurate eligibility redeterminations.

Assisters working in SBM states should check with their state about the process for renewing coverage and re-determining advance premium tax credit eligibility.

How will the auto-enrollment process work for enrollees who do not select a new plan for 2021? 

If people enrolled in coverage through the FFM don’t select a plan for 2021 by the time open enrollment ends on December 15, 2020, they will be automatically re-enrolled into the same plan they currently have. If the enrollee’s current plan is no longer offered, HealthCare.gov will enroll him in a new plan that is as similar as possible to his 2020 plan, based on a hierarchy established in regulations.

It is possible for people to be auto-enrolled into a plan that has a different type of network (e.g., HMO, PPO, or POS), or a different metal level. It is also possible an individual will be matched with a marketplace plan with a different insurer if the person’s current insurer is no longer offering any plans in the marketplace. In that case, enrollment will not be effective until the enrollee pays the first month’s premium.

Information about the plan people will be auto-enrolled into will come from their insurer. Enrollees who receive a notice saying that their current plan will no longer be offered should return to HealthCare.gov to look at their options and make sure that that they are enrolled in a plan that best meets their needs. HealthCare.gov will send a notice to enrollees in this situation reminding them to return to the marketplace.

Can an enrollee change plans once they are auto-enrolled in a plan? 

This depends. Open enrollment ends December 15, 2020. Enrollees who don’t come back to the marketplace to update their application and select a plan by the December 15 deadline will be auto-enrolled in a plan for 2021.

Those who are auto-enrolled into the same plan they had in 2020 will not be able to switch plans after that deadline. If an enrollee wishes to disenroll from the plan without incurring any premium payments in the 2021 coverage year, she will need to terminate her plan by December 31, 2020. Enrollees can cancel a plan by contacting the marketplace.

Those who are auto-enrolled into a different plan than the one they had in 2020 will be eligible for a special enrollment period (SEP) beginning January 1, 2021 due to the discontinuation of their 2020 plan. They will have 60 days before or after January 1, 2021 to switch to another plan if they choose to use the SEP. (For more information on SEPs, please see the Special Enrollment Period Reference Chart.)

View all key facts

In this Health Reform: Beyond the Basics webinar presented by the Center on Budget and Policy Priorities on October 8, 2019, Tara Straw, Senior Policy Analyst, provides and overview of the Healthcare.gov auto-renewal process for 2020 coverage, including the process for plan enrollment and redetermination of premium tax credit eligibility.

↓ View Presentation Slides (PDF)

Watch the Webinar

Additional Resources

Key Facts: The Premium Tax Credit

OE7 Webinar: Eligibility Rules for Premium Tax Credits

Beyond the Basics Webinar Series | View all webinars

Key Facts About Health Reform | View all key facts

Tools and Resources | View all tools and resources

Frequently Asked Questions | View FAQs

In this Health Reform: Beyond the Basics webinar presented on September 27, 2018, Shelby Gonzales, Senior Policy Analyst, provides an explanation of the Healthcare.gov auto-renewal process for 2019 coverage and discusses both the process for plan auto-enrollment and redetermination of eligibility for the premium tax credit.

Presentation Slides

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Watch the Webinar

Overview: Auto-Renewal Process and Notices

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Two-step auto-renewal process

Renewal notices

• Marketplace open enrollment notices (MOEN)
• Insurer notices
• If insurer is no longer offering plans in the Marketplace

Redetermination of APTC

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Auto-renewal process for APTC

• Eligible for redetermination of APTC
• Not eligible for redetermination of APTC
• Not eligible for auto-renewal (Medicare Anti-Duplication Provision) OR (member of an enrollment group has Medicare coverage)

APTC redetermination process for following coverage year

Auto-Enrollment for 2019 Plans

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Auto-enrollment process

• Option 1: Auto-enrolled into current plan
• Option 2: Auto-enrolled into new plan
• Option 3: Auto-enrolled into new plan with new insurer

Canceling auto-enrollment for 2019

Special enrollment period: 2018 plan discontinued

Tips for assisters

Q&A

Additional Resources

Resources | View resources links

Beyond the Basics Webinar Series | View all webinars

Key Facts About Health Reform | View all key facts

Tools and Resources | View all tools and resources

Frequently Asked Questions | View FAQs

Eligibility for a Special Enrollment Period

December 18, 2017

People enrolled in 2017 Marketplace plans that are discontinued for 2018 are eligible for the special enrollment period (SEP) for people losing minimum essential coverage. People eligible for the loss of coverage SEP have 60 days before or 60 days after the date their previous coverage ends to enroll in or change plans. For people whose 2017 plans are discontinued for 2018 that date is December 31, 2017.

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Who is eligible for this SEP?

Anyone whose 2017 Marketplace plan was discontinued for 2018 is eligible for an SEP, including:

• People enrolled in 2017 plans with insurers who are no longer offering coverage in their area.
• People whose 2017 plan is being discontinued but their insurer is still offering other plans in the Marketplace.

Everyone whose plan is discontinued is eligible for the SEP regardless of whether or not they are auto-enrolled into a new plan for 2018, or they actively select a new plan for 2018.

Everyone enrolled in a 2017 plan should have received a notice from their insurer detailing whether or not their 2017 plan would be offered in 2018. People with 2017 Marketplace coverage fall into one of the following categories:

• Their plan is no longer available and no other plans are available through that insurer. These consumers will get a notice from their issuers indicating that their plan is not being offered the following year. No information about a new plan will be in this notice, but the Marketplace will generally auto-enroll these individuals in a new plan with a new insurer if they don’t return to the Marketplace. The new plan will send information to the consumer about how to effectuate their coverage. These consumers are eligible for an SEP.
• Their plan is no longer available and the insurer will auto-enroll the person in a new plan. People will get a notice from their insurer indicating that their plan is not being offered the following year, and that they will be automatically enrolled in a new plan if they don’t return to the Marketplace and select a different plan. These consumers are eligible for an SEP.
• Their plan is available in 2018 and the insurer will auto-enroll the person into the same plan. People will get a notice detailing any changes to their plan for 2018. People can choose to remain enrolled in this plan for 2018 or choose a new plan during open enrollment. They are not eligible for an SEP — even if there are significant changes to the provider network, the cost sharing structure, or other features of their plan — because their coverage was not discontinued.

How do eligible consumers activate this SEP?

Consumers can activate this SEP online on HealthCare.gov or by calling the marketplace call center and indicating they have lost coverage just as they would if they lost other coverage from another source such as Medicaid or employer sponsored insurance. Two questions on the application ask if anyone in the household lost coverage in the past 60 days or if anyone is losing coverage in the next 60 days. Depending on whether it is before or after December 31, 2017, consumers should answer one of these questions affirmatively, and they should put December 31, 2017 as the date they are losing or have already lost coverage. This will trigger an SEP and allow consumers to enroll in a new plan. Consumers have until March 1, 2018 (60 days after December 31, 2017) to activate this SEP and choose a new plan. The coverage effective date of the new plan will be the first day of the month following plan selection. Eligible consumers should use this SEP as soon as possible to avoid potential gaps in coverage or being auto-enrolled in a plan that does not meet their needs.

When the discontinued plan was a Marketplace plan offered through HealthCare.gov, consumers should not have to submit documentation verifying the loss of coverage. However, if a person is asked to submit documentation, she can use the notice received from her insurer to prove that her coverage was discontinued.

November 9, 2017

Under a recent Department of Health and Human Services (HHS) rule, insurers can opt to collect any past-due premiums from the last 12 months before allowing someone to enroll in a plan with the same carrier. The following questions and answers explain who is affected by this new policy and how much they’ll owe.

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What is a past-due premium?

A past-due premium is an unpaid enrollee premium for a month of marketplace coverage. This can happen, for example, when an enrollee misses a premium and enters a three-month grace period, but fails to catch up on premiums. Coverage is terminated effective the last day of the first month of the grace period. The enrollee still owes that month’s premium, and it is considered past-due.

Who may be charged a past-due premium?

Effective June 19, 2017, an individual or employer who seeks to enroll in marketplace coverage with the same insurer (or a related insurer) after missing a premium payment within the last 12 months may be responsible for paying the past-due premium before the new enrollment will become effective, if the insurer has adopted a policy requiring payment of past-due premiums. For insurers that adopt this policy, payment of the past-due premium is necessary to effectuate coverage. Insurers’ ability to charge past-due premiums may be limited by state law. Check with your state insurance commissioner to find out if your state allows insurers to condition future enrollment on payment of past-due premiums.

What steps must an insurer take before charging someone a past-due premium?

To implement this policy, insurers must follow certain rules. The insurer must provide notice of the adoption of the past-due premium policy and the consequence of non-payment to the enrollee prior to the enrollee’s failure to pay a premium, either through a paper or electronic notification. The insurer must also provide notice of this policy in any communication about the past-due premium. In addition, the insurer can only seek to collect the past-due premium from the person who was contractually obligated to pay the premium (i.e., an insurer cannot demand a past-due premium from family members of the person who was obligated to pay the premium.) Insurers may only seek payment of premiums owed in the last 12 months (and no earlier than June 19, 2017). Insurers must still act consistent with state law.

Will people be aware that they may need to pay a past-due premium to effectuate coverage for 2018?

The full amount owed, including any past-due premium, will appear on the billing statement for January coverage. If consumers question a bill, because it is larger than anticipated, assisters should inquire about the possibility that the insurer is seeking payment of a previous unpaid premium. Consumers should have been given proper notice both before the non-payment and on the notice of non-payment.

Can a person pay January’s premium now and the past-due premium later?

No, an applicant cannot pay the binder payment first. Any payment received by the insurer is first applied to the oldest charge (i.e., the past-due premium), then any remainder is applied to the binder payment. Failure to make the full binder payment by the time specified by the plan will lead to cancellation of the policy.

How is a past-due premium calculated?

The past-due premium is the consumer’s share of the premium after applying any advance payments of the premium tax credit (APTC) paid in that month. In many cases, the amount of the past-due premium will be limited to one month because of the application of the grace period. A person who receives APTC is entitled to a three-month grace period to catch up on missed premiums before coverage is terminated. If premiums aren’t paid in full by the end of the third month, coverage is terminated as of the end of the first month. Therefore, the past-due premium owed is only for one month. However, if an enrollee is still in the grace period when he attempts to enroll in the new plan, the past-due premium will include all unpaid premiums during the grace period months. For example, if no payment is made in November or December and the grace period applies, the enrollee will still be in the grace period when the January payment is due; therefore, the enrollee will owe payments for November, December and January in order to effectuate January’s coverage.

Does the past-due premium policy affect enrollment in coverage under a special enrollment period (SEP)?

Yes. Payment of past-due premiums will be required to enroll in a plan through the same or related insurer through a SEP as well as during open enrollment.

How does the rule work for a person who doesn’t get APTC?

In general, it works the same way. However, if a person doesn’t collect APTC, the insurer treats past-due premiums according to state law; the marketplace’s grace period rules only apply to people with APTC. State laws vary on the timing of termination due to non-payment (i.e., whether coverage ends as of the last day of the last paid month, or whether coverage ends at some future date, such as after a 30-day notice period.) If there is still a balance owed from prior coverage under state rules, the insurer can demand it when the person tries to renew coverage. If state rules allow issuers to terminate coverage retroactive to the end of the last month paid, there may be no past-due premium to pay.

How does this policy apply to someone who is auto-reenrolled?

If someone is auto-reenrolled (or actively reenrolls) in the same plan, she must catch up on overdue premiums for 2018 coverage to take effect. For example, if a person stops paying her premium in November and enters a grace period, then attempts to enroll in the same plan or in a different plan with the same insurer, she must pay November, December and January’s payment by the end of January to remain covered. If not, coverage will be terminated as of November 30 and 2018 coverage will be cancelled.

Example 1:

Sam was enrolled with Insurer A in 2017 with APTC and received a notice in July that past-due premiums would be collected as a condition of re-enrollment. He failed to pay the premium for August coverage and doesn’t make any payments during the grace period so, at the end of October, his coverage is terminated effective August 31. His notice of non-payment stated the insurer’s past-due premium policy. If Sam attempts to enroll with the same insurer for 2018 coverage, he will need to pay his share of the August premium plus his January payment to have his 2018 coverage effectuated.

Example 2:

The situation is the same as in Example 1, except Sam paid all of his premiums until November. He didn’t make a payment for the rest of the year. During open enrollment, he chooses the same plan. He receives his bill for January’s payment in December, and it is due by January 10. As of the billing date, he is still in the grace period and will owe past-due premiums for November, and December, in addition to his January payment. Any payment made prior to the expiration of the grace period on January 31 will be applied to his earliest past-due premium first.

Example 3:

Artemis was enrolled in 2017 coverage with APTC and received a notice that past-due premiums would be collected as a condition of re-enrollment. She had an unresolved income data matching issue and lost her APTC in April. She was billed for the entire premium in April and couldn’t afford to pay. Because she was not receiving APTC in April, she was not given a grace period and her coverage was terminated, effective April 30, according to state law. Her window for filing an appeal on the loss of APTC has closed. If she attempts to enroll in a plan with the same insurer for 2018, she will owe a past-due premium for the full April premium plus January’s payment. However, if state laws on non-payment provide for a termination of coverage at the end of the last month paid, she will have no past-due premium and will only owe January’s payment.

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