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Via Facsimile and U.S. Mail
Mail Stop 6010

      July 21, 2005

Mr. Roy T.K. Thung
President and Chief Executive Officer
Independence Holding Company.
96 Cummings Point Road
Stamford, Connecticut   06902

      Re:	Independence Holding Company
		Form 10-K for Fiscal Year Ended December 31, 2004
		Filed March 16, 2005
      File No. 001-32244

Dear Mr. Thung:

      We have limited our review of your filing to only those
issues
we have addressed in our comments.  In our comments, we ask you to
provide us with information so we may better understand your
disclosure.  Please be as detailed as necessary in your
explanation.
After reviewing this information, we may raise additional
comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Item 7.  Management`s Discussion and Analysis of Financial
Condition
and Results of ...

Critical Accounting Policies

Insurance Reserves

1. For each of your health insurance products, provide us the
following information in disclosure-type format to help us
evaluate
the adequacy of your health insurance reserves:

* The amount accrued as of the latest balance sheet date
presented,
the total of which should agree to the amount presented on the
balance sheet.
* The amount of reserves for IBNR losses, separately from reported
losses.
* The range of loss reserve estimates as determined by your
actuaries.
* The key assumptions used to arrive at your best estimate of loss
reserves within that range and what specific factors led you to
believe this amount, rather than any other amount within the
range,
represented the best estimate of incurred losses.
* A discussion that explains the judgments and uncertainties
surrounding this estimate and the potential impact on your
financial
statements.

2. As you appear to have significantly revised your estimate of
health insurance reserves recorded in prior years, please provide
us
the following information in disclosure-type format to help us
evaluate the adequacy of your disclosure regarding  these changes
in
estimate:

* Identify the years to which the change in estimate relates and
disclose the amount of the related loss reserve as of the
beginning
of the year that was re-estimated.  Discuss and quantify
offsetting
changes in estimates that increase and decrease the loss reserve.
* Identify the changes in the key assumptions made to estimate the
reserve since the last reporting date.
* Identify the nature and timing of the change in estimate,
explicitly identifying and describing in reasonable specificity
the
new events that occurred or additional information acquired since
the
last reporting date that led to the change in estimate.
* Ensure the disclosure clearly explains why recognition occurred
in
the periods that it did and why recognition was not required in
earlier periods.
* Disclose any trends such as, the number of claims incurred,
average
settlement amounts, number of claims outstanding at period ends
along
with average per claim outstanding, and any other trends,
necessary
to understand the change in estimate. Please explain the rationale
for a change in estimate that does not correlate with trends.

Consolidated Financial Statements

Notes to Consolidated Financial Statements

Note 1.  Significant Accounting Policies and Practices

3. Please provide us, in disclosure-type format, to help us
evaluate
your accounting and the adequacy of your disclosure how you apply
the
following policies to your health, versus life, insurance
policies:
(a) deferred acquisition costs, (b) insurance reserves, and (c)
premium revenue.

(I)  Deferred Acquisition Costs ("DAC")

4. We note that you adjust DAC each quarter to reflect revised
best
estimate assumptions and that any resulting DAC unlocking
adjustments
are currently reflected.  Please tell us  (a)  how often you
recognize unlocking adjustments (not just to DAC), (b) the reasons
for the adjustments, (c) the financial statement line items
affected
and (d) by what amounts and how your accounting complies with FAS
60.

*    *    *    *

	Please respond to these comments within 10 business days or
tell
us when you will provide us with a response.  Please furnish a
response letter that keys your responses to our comments and
provides
any requested information.  Detailed letters greatly facilitate
our
review.  Please file your letter on EDGAR under the form type
label
CORRESP.  Please understand that we may have additional comments
after reviewing your responses to our comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing include all information required under the Securities
Exchange
Act of 1934 and that they have provided all information investors
require for an informed investment decision.  Since the company
and
its management are in possession of all facts relating to a
company`s
disclosure, they are responsible for the accuracy and adequacy of
the
disclosures they have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and

* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

      You may contact Ibolya Ignat, Staff Accountant, at (202)
551-
3656, or Oscar M. Young, Senior Staff Accountant, at (202) 551-
3622,
if you have questions regarding the comments. In this regard, do
not
hesitate to contact me, at (202) 551-3679.

								Sincerely,

								Jim B. Rosenberg
								Senior Assistant Chief
								Accountant

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Roy T.K. Thung
Independence Holding Company
July 21, 2005
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