Will She Have to Pay ACA Penalty for these Lapses in Coverage

losing EGHP 8/30/17 and T65 stsrting medicare in march 2018.She does have a cobra option but wants to save buy getting a STM.

if she does cobra for month of September and then goes the last 3 months of 2017 without ACA coverage then no penalty right?

she would only be going January and February 2018 without ACA so no penalty there right?

would you advise her to keep the cobra for 2017 just to be safe?
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