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    Strength. Vision. Stability.

May 21, 2020

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Finance

100 F Street, NE,

Washington D.C. 20549

Re: INDEPENDENCE
HOLDING CO

Form
10-K for the Fiscal Year Ended December 31, 2019

Filed
March 16, 2020

File No. 001-32244

Dear Sir or Madam:

This letter is being furnished in response
to comments contained in the letter dated May 11, 2020 from the staff (the “Staff”) of the United States Securities
and Exchange Commission (the “Commission”) to Ms. Teresa A. Herbert, Chief Financial Officer of Independence
Holding Company (“IHC”), with respect to IHC’s Annual Statement on Form 10-K filed with the Commission
on March 16, 2020.

The text of the Staff's comments is set
forth below, followed by IHC’s responses.

Capitalized terms not otherwise defined
herein shall have the meanings ascribed to such terms as set forth in the Form 10-K filed with the Commission on March 16, 2020.

Form 10-K for the fiscal year ended December 31, 2019

Notes to Consolidated Financial Statements

Note 11. Policy and Benefits Claims,
page 87

We note the activity in the reserves for
losses and loss expenses on pages 87-88 present a favorable development of $20,294,000 for prior years losses and loss expenses
including $5,879,000 in specialty health reserves and $11,681,000 in the group disability reserves; however, the tables that you
present on pages 88-92 appear to depict favorable development of approximately $7.8 million for group disability reserves and $5.7M
for specialty health reserves. Further, the claims paid related to prior years for both Specialty Health and Group Disability of
$37.5M are significantly lower than the $54.7M shown in the rollforward table on page 87. We also note that the objective of the
short-duration disclosures as outlined in paragraph BC 2 of ASU 2015-09 is to provide financial statement users with information
to facilitate analysis of the amount, timing, and uncertainty of cash flows arising from insurance contracts and the development
of loss reserve estimates. Please address the following:

      1

 1. Explain to us, and revise your disclosures in future filings to provide a more granular discussion
of the differences relating the favorable assessments and claims paid noted above. It might be useful to provide a reconciliation
to support your discussion.

 2. Explain to us the lines of business not included in the tables and quantify the prior year development
for those lines in 2019.

 3. Explain why you do not include the lines of business identified in the preceding bullet in your
tables, and provide your consideration for disclosing such information.

Response:

In this response, we have included revised
Note disclosures for 2019 as recommended by your office with more granular discussions and reconciliations. These revised Note
disclosures will be included in future filings. The revisions include:

 (i) the presentation of the policy benefits and claims rollforward disaggregated into four major categories
(Specialty Health business, DBL and PFL business, group disability business, and all other lines) and in total. The Specialty Health,
DBL and PFL business and the group disability business columns each correspond to the claims development tables and disclosures
that follow the policy benefits and claims rollforward; and

 (ii) quantitative disclosures of amounts incurred related to prior years by line of business
within certain categories, as defined above, that is in a tabular format and reconciles to the policy benefits and claims rollforward.

The new presentation of the policy benefits
and claims rollforward quantifies prior year developments for all other lines not presented in claims development tables. All other
lines consist primarily of life, other individual health products and our medical stop-loss business in run-off.

In addition, we have added language in
the revised Note disclosures preceding the DBL and PFL claims development table to explain and quantify the amounts incurred
and paid related to prior years that are not included in the DBL and PFL development table for reasons discussed in more
detail below. These disclosures, as revised, will be included in future filings.

      2

Specialty Health

Most lines in the Specialty Health segment
are fully developed within 5 years and as such we present the claims development table with 5 years of data. However, included
in the Specialty Health segment is our occupational accident line that tends to develop over a slightly longer period. The differences
between the amounts shown in the rollforward for the Specialty Health segment ($5,879,000 of favorable development incurred
for prior years and $23,647,000 of amounts paid for prior years), and the amounts depicted in the 5-year Specialty Health
claims development table ($5,693,000 of favorable development incurred for prior years and $23,482,000 of amounts paid
for prior years) is $186,000 in amounts incurred and $165,000 of amounts paid that is primarily related to occupational
accident claims for accident years prior to 2015.

DBL and PFL, and Group Disability

Our DBL and PFL business is very short
tail in nature and the claim liabilities are typically developed in less than one year. Any DBL and PFL amounts incurred or paid
for prior calendar years is recognized in the first few months of the following calendar reporting year. Those claims are fully
developed early in the calendar year. The development table presented for DBL and PFL business depicts the claims development for
amounts that are included in the benefits and claims reserves on the balance sheet date, and that ending liability for IBNR plus
expected claims development is all related to the current accident year.

We revised and added additional language
preceding the 2019 DBL and PFL claims development table to explain and quantify the above information as follows:

“Less than one
year of claims development data is presented below for our DBL and PFL claim liabilities as claims develop in under one year. At
December 31, 2019, the liability for IBNR plus expected development related to our DBL and PFL business was $22,774,000 and (i)
relates entirely to the current accident year; and (ii) includes an accrual for a potential risk adjustment payment of $10,000,000
associated with the PFL rider due to expected better than industry claims experience and $2,400,000 of DBL premium refund reserves
to meet the mandated minimum loss ratio requirements. Prior year favorable incurred development of $6,489,000, and amounts
paid related to prior years of $13,747,000, were recognized in the first few months of the 2019 calendar year on DBL and PFL business.
Claim liabilities corresponding to these amounts were fully developed early in 2019, and no liability for IBNR or expected claim
development was remaining at December 31, 2019.”

After inserting the above language, the
DBL and PFL claims development disclosures, together with the group disability claims development tables, reconcile to the favorable
amounts incurred related to prior years as shown in the policy benefits and claims liability rollforward as follows:

    DBL and PFL, now shown in policy benefits and claims rollforward
    $ 6,489

    Group disability, undiscounted
      7,835

    Group disability, impact of discounting
      (2,643 )

         Group disability, discounted, now shown in policy benefits and claims rollforward
      5,192

    Total DBL, PFL and group disability, as previously disclosed
    $ 11,681

      3

Claims Paid Related to Prior Years

After revising the presentation of the
policy benefits and claims rollforward and inserting the above DBL and PFL language, the claims development disclosures and tables
reconcile to the amounts paid related to prior years as shown in the policy benefits and claims liability rollforward as
follows:

    Specialty Health, per claims development table
    $ 23,482

    Specialty Health, payments for accident years prior to 2015
      165

         Specialty Health, now shown in policy benefits and claims rollforward
      23,647

    DBL and PFL, now disclosed in language preceding claims development table and

         shown in policy benefits and claims rollforward
      13,747

    Group disability, per claims development table
      14,001

    Group disability, payments for accident years prior to 2010
      1,229

         Group disability, now shown in policy benefits and claims rollforward
      15,230

    All other lines, now shown in policy benefits and claims rollforward
      2,071

         Total claims, prior years, disclosed in policy benefits and claims rollforward
    $ 54,695

      4

Note 11.	Policy Benefits and Claims	(REVISED
for 2019)

Policy benefits and
claims is the liability for unpaid loss and loss adjustment expenses. It is comprised of unpaid claims and estimated IBNR reserves.
Summarized below are the changes in the total liability for policy benefits and claims for the periods indicated (in thousands).

    2019

    Specialty
    DBL and
    Group
    All Other

    Health
    PFL
    Disability
    Lines
    Total

    Balance at beginning of year
    $ 38,363
    $ 21,080
    $ 82,222
    $ 18,450
    $ 160,115

    Less: reinsurance recoverable
      1,335
      719
      24,712
      11,356
      38,122

    Net balance at beginning of year
      37,028
      20,361
      57,510
      7,094
      121,993

    Amount incurred, related to:

       Current year
      82,678
      65,452
      31,463
      16,531
      196,124

       Prior years
      (5,879 )
      (6,489 )
      (5,192 )
      (2,734 )
      (20,294 )

       Total incurred
      76,799
      58,963
      26,271
      13,797
      175,830

    Amount paid, related to:

       Current year
      49,669
      42,803
      11,794
      11,053
      115,319

       Prior years
      23,647
      13,747
      15,230
      2,071
      54,695

       Total paid
      73,316
      56,550
      27,024
      13,124
      170,014

    Net balance at end of year
      40,511
      22,774
      56,757
      7,767
      127,809

    Plus:  reinsurance recoverable
      1,717
      664
      23,322
      11,290
      36,993

    Balance at end of year
    $ 42,228
    $ 23,438
    $ 80,079
    $ 19,057
    $ 164,802

Since unpaid loss and
loss adjustment expenses are estimates, actual losses incurred may be more or less than the Company’s previously developed
estimates and is referred to as either unfavorable or favorable development, respectively.

Net favorable development
in the Specialty Health segment was comprised of the following lines of business for the period indicated (in thousands):

    2019

    Short-term medical
    $ 1,850

    Occupational accident
      2,054

    Limited Medical
      474

    Critical illness
      325

    All other lines
      1,176

         Total Specialty Health
    $ 5,879

Specialty Health net
favorable development occurred primarily in the short-term medical and occupational accident lines of business. Favorable development
in short-term medical business was due to paid claim activity that was below anticipated levels as medical investigations were
completed and the reliability of claim payment patterns at a newer claim administrator emerged. Additionally, favorable development
occurred in the occupational accident line, in run-off, mainly due to some claims settling for amounts less than anticipated and
due to a lower level of employer liability claims than anticipated in relation to historical levels, and favorable development
in other various lines of Specialty Health business primarily due to better than expected claim development.

      5

The net favorable development
of $6,489,000 in the DBL and PFL business is mainly due to favorable adjustments to prior year DBL premium refund reserves in addition
to better than expected DBL claims experience.

Favorable development
of $5,192,000 in the group disability business is primarily due to the LTD business. The LTD line experienced better than expected
claim development in terms of duration and net payments.

All other lines, primarily
life and other individual health products and including our medical stop-loss business in run-off, experienced favorable development
of $2,734,000. The favorable development is primarily related to the group term life business due to continued improvements in
experience and updated assumptions for the Paid-Up Life business.

Specialty Health Segment

The following tables
provide undiscounted information about net incurred and paid claims development by accident year for significant short-duration
contract liabilities for policy benefits and claims in our Specialty Health segment. All amounts are shown net of reinsurance.
In addition, the tables present the total IBNR plus expected development on reported claims by accident year and the cumulative
number of reported claims (in thousands, except number of reported claims). Refer to Note 1 for information on the methods we use
to estimate IBNR plus expected development, as well as changes to those methodologies and assumptions. Five years of claims development
data is presented for lines that are included in our Specialty Health segment since a majority of the claims are fully developed
in that time. Certain information about incurred and paid claims is presented as supplementary information and unaudited where
indicated.

    Specialty Health Segment –Claims Development

    December 31, 2019

    Incurred Claims and Claim Adjustment Expenses, Net of Reinsurance
    Incurred But
    Cumulative

    For the years ended December 31,
    Not Reported
    Number of

    Accident
    2015
    2016
    2017
    2018

    Plus Expected
    Reported

    Year
    (unaudited)
    (unaudited)
    (unaudited)
    (unaudited)
    2019
    Development
    Claims

    (Actual)

    2015
    $ 104,497
      100,988
      101,241
      100,642
    $ 101,260
    $ 293
      467,232

    2016

      85,426
      86,446
      86,244
      85,399
      1,161
      538,382

    2017

      87,070
      77,214
      77,194
      1,275
      628,748

    2018

      74,652
      69,206
      4,259
      661,819

    2019

      82,926
      33,257
      537,636

      Total
    $ 415,985

      6

    Specialty Health Segment –Claims Development

    Cumulative Paid Claims and Claim Adjustment Expenses, Net of Reinsurance

    For the years ended December 31,

    Accident
    2015
    2016
    2017
    2018

    Year
    (unaudited)
    (unaudited)
    (unaudited)
    (unaudited)
    2019

    2015
    $ 70,090
      94,757
      97,603
      99,364
    $ 100,967

    2016

      45,454
      78,611
      82,983
      84,238

    2017

      49,289
      73,667
      75,918

    2018

      46,574
      64,947

    2019

      49,670

    Total
    $ 375,740

    Outstanding policy benefits and claims payable before 2015, net of reinsurance
      266

    Total policy benefits and claims, net of reinsurance
    $ 40,511

The claim frequency
information consists of the count of claims submitted. Each claim was counted as one claim whether or not multiple claim lines
were submitted with that claim, and each claim was counted whether or not it resulted in a liability. For those portions of business
that did not have claim records readily available, a reasonable count assumption was made based on a comparison to the known records
of a similar business type. Cumulative claim count information is not a precise tool for calculating claim severity. Factors, such
as changes in provider billing practices, the mix of services, benefit designs or processing systems could impact this type of
analysis. The Company does not necessarily use the cumulative number of reported claims disclosed above in its claims analysis
but has provi