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@KathyJo wrote:

 I do believe that it does not qualify because it is a subsidized plan. 

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A subsidized plan does not disqualify it.  The restriction is if it is subsidized by an employer.  In my opinion, there is no employer, so that is not an issue.

I think the issue is if the "plan" is "established" under the self employed business.  It is definitely a "gray area", but based on the Medicare rulings, I lean towards it qualifying.