"Whereas most health indemnity policies are fully insured, ... benefits under the self-funded health indemnity plan lacked economic substance in that payments could be made for merely completing a health risk assessment or calling a health coach. The IRS issued a Chief Counsel Memorandum (CCM) on this arrangement in early 2016, and in a recent follow-up CCM, the IRS exposed the fatal defects under the self-insured program. As discussed herein, however, some overly broad statements in the most recent CCM appear to be contrary to established law with regard to more traditional fully insured health indemnity plans."