The insurer failed to notify Sausen that it would not renew the policy, and two months after the expiration date, the combine was damaged by fire. The insurer disagreed, arguing that its failure to provide notice only resulted in its implied offer of renewal, which must be accepted by the policyholder before the policy expiration date for the policy to be renewed. The court of appeals held that notice of nonrenewal or of premium due is required under the statute before a policy lapses and that, because such notice was not provided by the insurer, Sausen's coverage extended beyond the expiration date. Our holding is consistent with the holding in Sausen . We, like the Sausen court, recognize that, pursuant to Wis. Stat.
Coverage continues, barring any exceptions, under a renewal of the policy.
This conclusion promotes mandatory notice. Our holding, however, goes one step further than Sausen because we also find that the continuation of coverage is limited to one renewal period. Indeed, the Sausen court did not have to address this issue because the date of the accident in that case fell within this renewal period. Notwithstanding any renewal of the policy, NSM also argues that it is entitled to coverage under its policy because the policy remained in effect after Frazin's policy was not renewed. The terms of the policy required that all NSM physicians have individual professional liability policies with the same limits of liability.