In Ex parte Whitehead, 908 S.W.2d 68, 71 (Tex. App.--Houston 1st Dist. 1995, orig. proceeding), a child support order was held to be unenforceable by contempt for a number of reasons, including that "the divorce decree did not order the father to pay any amount of money to anybody at anytime for insurance" but instead just ordered the father "to keep and maintain health insurance on the children 'at all times.'" Id.
The appellate court specifically noted that its opinion was "concerned only with the legality of the contempt findings" and did not affect the trial court's money judgment in favor of the mother, which included the unpaid health insurance. Id. at 71 n.3.