When active power devices are operated at dissipations approaching their maximum ratings (after including appropriate derating factors, heatsink properties and safety margins), the case-heatsink thermal resistance sometimes makes up a significant part of the total J-A thermal circuit. Some devices like those in variants of TO-220 and TOP3 packages are offered with a choice of bare metal or insulated mounting tabs. Datasheets often do not make any distinction between the two versions regarding their case-heatsink thermal resistances.
Would it be reasonable to assume that the c-hs Rth of an insulated case is about the same as that of a bare metal case mounted with a mica insulator (using a thermal paste in each case)?