Maybe???
Before a couple of months ago, the answer was "no". But a couple of months ago the IRS/Treasury released some PROPOSED Regulations that state for purposes of a Medical Deduction, Heathcare Ministries can now count as insurance.
But two cautions: (1) It is only a PROPOSED Regulation. It does have some authority, but the IRS is not bound by it and (2) The Regulation says it is insurance for Section 213 of the Tax Code, but does NOT address the Self Employed Health Insurance deduction.