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Tirosint HSA/FSA Eligibility and Submission: A Complete 2026 Guide

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At a glance

  • Drug / Tirosint (levothyroxine sodium) liquid gel capsule, 13 mcg to 150 mcg strengths
  • Manufacturer / IBSA Pharma Inc.
  • HSA eligible / Yes, as a qualified medical expense per IRS Publication 502
  • FSA eligible / Yes, including Limited-Purpose FSA when prescribed
  • Typical retail cost / $200, $400 per 30-day supply without insurance
  • Manufacturer savings card / IBSA Tirosint Savings Card (up to $150 off per fill, limits apply)
  • Submission method / benefit card at pharmacy OR manual claim with itemized receipt
  • Key IRS rule / Requires a valid prescription; OTC drugs need a prescription for FSA since CARES Act 2020
  • FDA approval / NDA 201831 (Tirosint); NDA 206977 (Tirosint-SOL)
  • Bioavailability advantage / Gel cap reaches ~99% absorption vs. ~70 to 80% for standard tablets in some malabsorption conditions

What Makes Tirosint an HSA/FSA-Eligible Expense

Tirosint qualifies for HSA and FSA reimbursement because it is an FDA-approved prescription drug used to treat a diagnosed medical condition, specifically hypothyroidism and thyroid cancer suppression therapy. The IRS defines "qualified medical expenses" in Publication 502, which explicitly includes prescription medications. Because levothyroxine is prescribed only for diagnosed thyroid disease, it clears every IRS threshold without ambiguity.

The CARES Act of 2020 expanded FSA eligibility to include many over-the-counter drugs when accompanied by a prescription, but Tirosint has always required a prescription, so that change did not affect its status, it was eligible before 2020 and remains so now.

The FDA approved Tirosint capsules under NDA 201831 and Tirosint-SOL (the liquid solution) under NDA 206977. Both formulations carry the same IRS eligibility because both are FDA-approved prescription products. [1]

Why Tirosint Differs from Generic Levothyroxine

Standard levothyroxine tablets (Synthroid, Euthyrox, generics) contain excipients including lactose, acacia, and dyes. Tirosint's gel cap formulation contains only levothyroxine sodium, glycerin, gelatin, and water, four ingredients. That minimal formula was designed to reduce absorption variability in patients with lactose intolerance, celiac disease, or post-bariatric anatomy.

A pharmacokinetic study published in Thyroid (2013) found that Tirosint produced statistically equivalent area-under-the-curve (AUC) thyroid hormone levels to reference levothyroxine, with reduced inter-subject variability. [2] The FDA's own product labeling notes that levothyroxine absorption can be affected by gastrointestinal conditions and co-administered foods. [1]

Because Tirosint is a brand-name product with no AB-rated generic gel-cap equivalent as of early 2026, its cost is higher than generic tablet levothyroxine, making HSA/FSA optimization especially relevant for patients on this formulation.

IRS Publication 502 and the Prescription Requirement

IRS Publication 502 (updated annually) defines a qualified medical expense as "the costs of diagnosis, cure, mitigation, treatment, or prevention of disease." Prescription drugs are explicitly listed. [3] You do not need to itemize deductions on your federal tax return to use an HSA or FSA; these accounts provide tax savings regardless of whether you take the standard deduction.

One practical note: a Letter of Medical Necessity (LMN) is not required for Tirosint because it is a prescription-only drug. Your prescriber's valid prescription is sufficient documentation. Keep pharmacy receipts for at least three years in case of an IRS audit of your HSA distributions.


How to Submit an HSA Claim for Tirosint

Submitting Tirosint for HSA reimbursement follows a two-step process: pay at the pharmacy, then file a claim with your HSA administrator. Most administrators accept digital submission.

Step 1: Collect the Right Documents

Your HSA administrator will require an itemized pharmacy receipt that shows:

  • Patient name
  • Date of service
  • Drug name (Tirosint or levothyroxine sodium gel capsule)
  • Strength and quantity dispensed
  • Amount paid out of pocket

An Explanation of Benefits (EOB) from your insurer is not mandatory for HSA claims but speeds processing. If you paid cash (no insurance), the pharmacy receipt alone is typically sufficient. The American Diabetes Association's guidance on HSA documentation practices notes that itemized receipts, not just credit card statements, are the required standard for substantiation. [4]

Step 2: File with Your HSA Custodian

Log into your HSA portal (Fidelity, HSA Bank, HealthEquity, Optum Bank, etc.) and manage to "File a Claim" or "Request Reimbursement." Upload the receipt as a PDF or image. Most custodians process claims within 3 to 5 business days. Funds are deposited to your linked checking account or can remain invested in the HSA.

There is no deadline to file an HSA claim in the same calendar year. Unlike an FSA, an HSA has no "use it or lose it" rule, you may reimburse yourself for a 2026 Tirosint purchase in 2028 or 2030, as long as the expense occurred after you opened the HSA and the account was funded at the time of purchase. [3]

Using a Benefit Debit Card at the Pharmacy

If your HSA or FSA came with a debit card, swipe it directly at the pharmacy counter. The card processes automatically for eligible prescriptions at most pharmacies in the Signet/Solutran network. Tirosint's prescription status means the card will approve without requiring the pharmacist to enter an override code.

Keep your receipt anyway. If your plan administrator flags the transaction for substantiation, you will need the itemized receipt to confirm eligibility. Failure to substantiate an FSA transaction may result in a corrective distribution taxed as income.


How to Submit an FSA Claim for Tirosint

FSA submission follows the same documentation rules as HSA but has one critical difference: most FSAs operate on a plan year with a "use it or lose it" feature. A grace period of up to 2.5 months or a rollover of up to $660 (IRS 2026 limit) may apply depending on your employer's plan design.

FSA Grace Period vs. Rollover

Employers may offer either a grace period or a rollover, not both. Under a grace period plan, expenses incurred through March 15 of the following year may be submitted against the prior year's balance. Under a rollover plan, up to $660 carries into the next plan year. Check your Summary Plan Description to identify which applies. If your Tirosint prescription fills in December, timing your submission correctly can prevent forfeiture of unspent FSA dollars. [3]

Limited-Purpose FSA Considerations

If you use a High-Deductible Health Plan (HDHP) paired with an HSA, your employer may offer a Limited-Purpose FSA (LP-FSA). LP-FSAs are restricted to dental and vision expenses until you meet your deductible, at which point the FSA may convert to a "post-deductible" FSA that covers prescriptions including Tirosint. Confirm your plan's conversion trigger with your HR benefits team before submitting.


How to Get Tirosint Cheaper: Stacking Savings Programs

Tirosint's retail cost without insurance runs approximately $200, $400 for a 30-count supply depending on strength and pharmacy. Three savings levers exist: manufacturer programs, pharmacy pricing tools, and HSA/FSA pre-tax funding itself.

IBSA Tirosint Savings Card

IBSA Pharma offers a co-pay savings card for commercially insured patients. As of early 2026, eligible patients may pay as little as $0 for a qualifying fill, with the savings card covering up to $150 per prescription. The card is not valid for Medicare, Medicaid, or other government-funded programs. Enrollment is available through the Tirosint manufacturer website or through participating pharmacies.

Patients who are uninsured may qualify for IBSA's Patient Assistance Program (PAP) instead. The PAP provides Tirosint at no cost to qualifying patients who meet income criteria (generally at or below 400% of the Federal Poverty Level). Applications are processed through the manufacturer's access program directly.

The table below shows how savings programs can be stacked for a commercially insured patient filling a 30-day supply of Tirosint 50 mcg at retail:

| Cost Layer | Amount | |---|---| | Retail price (no discount) | $310 | | After IBSA savings card ($150 off) | $160 | | After HSA/FSA pre-tax funding (22% bracket) | ~$125 effective cost | | Net out-of-pocket vs. Retail | ~60% reduction |

Note: Tax bracket savings are illustrative at a 22% marginal federal rate. State income tax savings add further benefit in states that recognize HSA deductions.

GoodRx and Cash-Pay Pricing

GoodRx and similar discount platforms negotiate cash-pay rates at participating pharmacies. Tirosint 50 mcg (30 capsules) may be available for $180, $250 via GoodRx coupons at major chains. You cannot use GoodRx simultaneously with insurance, and using a GoodRx coupon disqualifies the purchase from HSA/FSA reimbursement in most administrator interpretations because no prescription benefit was applied. Confirm with your HSA custodian before combining these programs.

Specialty and Mail-Order Pharmacies

Some specialty pharmacies compound levothyroxine in liquid or alternative delivery forms, but compounded levothyroxine is not Tirosint and is not AB-rated to Tirosint. The FDA has specifically noted concerns about compounded thyroid preparations and dosing consistency. [5] The Endocrine Society's 2019 clinical practice guideline on hypothyroidism management recommends using FDA-approved formulations when possible. [6]

Mail-order pharmacies (90-day supplies through CVS Caremark, Express Scripts, etc.) often offer a lower per-unit cost for maintenance medications. A 90-day Tirosint supply through mail order may cost 15 to 20% less per capsule than a 30-day retail fill, and the IBSA savings card may apply per fill rather than per 30-day period, confirm current terms with IBSA's program administrator.


Clinical Background: Why Some Patients Are Prescribed Tirosint Over Generic Levothyroxine

Understanding why a clinician prescribes Tirosint specifically (rather than generic levothyroxine tablets) matters for HSA/FSA documentation and for discussions with insurance utilization management.

Absorption Variability and Gastrointestinal Conditions

Levothyroxine absorption occurs primarily in the proximal small intestine. Standard tablet formulations require disintegration and dissolution before absorption. Several conditions reduce tablet absorption, including celiac disease, inflammatory bowel disease, Helicobacter pylori gastritis, and Roux-en-Y gastric bypass anatomy.

A 2015 study in the Journal of Clinical Endocrinology and Metabolism (JCEM) found that patients with autoimmune atrophic gastritis required significantly higher levothyroxine tablet doses to maintain TSH suppression compared to patients without gastric disease, suggesting impaired absorption. [7] Tirosint's gel-cap formulation bypasses the disintegration step, which may explain its more consistent absorption in these populations.

Lactose and Excipient Sensitivity

Generic levothyroxine tablets contain lactose as a filler. For patients with lactose intolerance or galactosemia, tablet formulations may cause gastrointestinal symptoms or impaired absorption. A 2017 study in Frontiers in Endocrinology found that switching lactose-intolerant hypothyroid patients from standard tablets to liquid levothyroxine improved TSH control and reduced gastrointestinal complaints. [8]

Because Tirosint contains no lactose, no gluten, no dyes, and no acacia, it is the preferred formulation in patients with confirmed excipient sensitivities. Documenting the clinical rationale in the medical record supports insurance prior authorization and, if needed, HSA/FSA administrator queries about medical necessity.

TSH Monitoring and Dosing Consistency

The American Thyroid Association (ATA) 2014 guidelines on hypothyroidism management specify that TSH should be measured 4 to 8 weeks after any levothyroxine dose change or formulation switch. [9] If a patient switches from generic tablet to Tirosint, TSH rechecks are needed because bioavailability differences may alter the effective dose. The FDA-approved labeling for levothyroxine products includes a black-box warning noting that narrow therapeutic index characteristics require careful dose titration and monitoring. [1]

Prescribers switching patients to Tirosint for clinical reasons, documented absorption failure on tablets, confirmed excipient intolerance, or post-bariatric anatomy, create a clear clinical record supporting the prescription's medical necessity, which is the backbone of both insurance coverage arguments and HSA/FSA eligibility.


Insurance Prior Authorization for Tirosint

Many insurance plans classify Tirosint as a non-preferred brand or Tier 3 drug and require prior authorization (PA) before covering it. Without a PA, the claim may deny, and the patient pays the full retail price. Knowing how to manage this process directly affects how much you will rely on HSA/FSA funds.

What Insurers Typically Require

PA criteria for Tirosint commonly include:

  • Documentation of inadequate TSH control on at least one generic levothyroxine tablet at an appropriate dose
  • Confirmed diagnosis of a condition impairing tablet absorption (celiac disease, post-bariatric surgery, atrophic gastritis)
  • Or confirmed excipient intolerance (lactose intolerance, dye allergy documented in medical record)

The Endocrine Society's position statement on levothyroxine therapy notes that "switching patients between levothyroxine formulations without clinical indication is not recommended" but also acknowledges that specific populations benefit from alternative formulations. [6] This statement supports PA approval when clinical documentation is thorough.

Appeals and the Step-Edit Process

If a PA is denied, you have the right to appeal under the ACA's internal and external appeal process. Your prescriber can submit a peer-to-peer review request, speaking directly with the insurer's medical director. Approval rates for peer-to-peer reviews for specialty brand medications typically improve when the treating physician documents specific clinical failures on generic alternatives. During the appeal process, HSA or FSA funds can cover the out-of-pocket cost without penalty, you are not forfeiting reimbursement rights by paying while an appeal is pending.


Levothyroxine Dosing and TSH Targets: Relevant Clinical Reference Points

Correct dosing of levothyroxine, regardless of formulation, is the foundation of thyroid disease management. HSA/FSA eligibility is unchanged by dose or indication, but patients often have questions about cost implications as doses change.

Standard Dosing Parameters

The typical starting dose for adult hypothyroidism is 1.6 mcg/kg/day of levothyroxine, titrated based on TSH response. [9] Tirosint is available in strengths from 13 mcg to 150 mcg. Patients requiring doses above 150 mcg may need split doses or combination with the liquid Tirosint-SOL (available in 25 mcg/mL). Each vial of Tirosint-SOL is a single-use ampule; quantity prescribed directly affects monthly cost and HSA budget planning.

For thyroid cancer suppression therapy, TSH targets are lower, often <0.1 mIU/L for high-risk patients, per ATA risk stratification. [9] Suppressive doses are higher than replacement doses, meaning monthly pill burden and cost are higher, making pre-tax HSA/FSA funding even more financially significant for this population.

Drug Interactions That Affect Absorption and Cost Planning

Several common drugs and supplements reduce levothyroxine absorption and may require dose increases, and therefore higher monthly costs. These include calcium carbonate (separate by at least 4 hours), ferrous sulfate (separate by at least 4 hours), proton pump inhibitors, cholestyramine, and soy-based products. [1] Patients on these agents may need larger Tirosint quantities to achieve target TSH, which amplifies the cost-savings value of HSA/FSA utilization.

A 2020 systematic review in Thyroid examined levothyroxine absorption interference by 27 drugs and foods, confirming that timing-based separation strategies effectively mitigate most interactions. [10] Documenting these interactions in the medical record also supports PA requests that argue for the gel-cap formulation's absorption reliability.


Record-Keeping Best Practices for HSA/FSA Audits

The IRS can audit HSA distributions up to three years after the tax return filing date. Keeping organized records protects you from unexpected tax liability.

What to Save

Keep the following for every Tirosint purchase submitted to HSA or FSA:

  • Itemized pharmacy receipt (not just a credit card statement)
  • Prescription label or pharmacy printout confirming the drug name and prescriber
  • EOB from your insurer (if applicable)
  • Any HSA custodian confirmation of reimbursement

Digital storage in a dedicated folder (cloud or local) is acceptable. The IRS does not require paper originals.

What Happens if Documentation Is Inadequate

If an HSA distribution cannot be substantiated as a qualified medical expense, the amount is included in gross income and subject to an additional 20% penalty tax. For an FSA, unsubstantiated claims may trigger corrective action by the plan administrator including plan disqualification in extreme cases. [3] Given Tirosint's cost, the tax penalty on an unsubstantiated claim could exceed $60, $80 per fill in the 22% bracket plus penalty. Proper documentation is straightforward and the risk of inadequate records is easily avoided.


Comparing Tirosint-SOL and Tirosint Gel Cap: HSA/FSA Implications

Both Tirosint (gel cap, NDA 201831) and Tirosint-SOL (liquid solution ampules, NDA 206977) are FDA-approved levothyroxine formulations from IBSA. [1] Both are fully HSA/FSA eligible as prescription medications.

Tirosint-SOL is used primarily in patients who cannot swallow capsules, including infants and children, patients with severe dysphagia, and certain tube-fed patients. The liquid ampules are typically dispensed in quantities matching the prescribed daily dose, and cost per mcg is generally higher than the gel-cap formulation.

For HSA/FSA budgeting: if your plan year allows $3,200 in FSA contributions (2026 IRS individual limit) or you have accumulated HSA funds, a 90-day supply of Tirosint-SOL at suppressive doses could consume $500, $900 or more. Planning contributions to align with recurring prescription costs is a standard financial optimization strategy.


Frequently asked questions

Can I use my HSA to pay for Tirosint?
Yes. Tirosint is an FDA-approved prescription drug for a diagnosed medical condition (hypothyroidism or thyroid cancer). The IRS classifies prescription medications as qualified medical expenses under Publication 502, making Tirosint fully HSA-eligible. Pay at the pharmacy with your HSA debit card or pay out of pocket and submit a reimbursement claim with an itemized receipt.
Can I use my FSA to pay for Tirosint?
Yes. Tirosint qualifies for FSA reimbursement for the same reason it qualifies for HSA: it is a prescription drug for a diagnosed condition. Unlike HSAs, FSAs typically have a plan-year deadline, so submit claims before your FSA's run-out or grace period ends to avoid forfeiture.
Does Tirosint require a Letter of Medical Necessity for HSA or FSA?
No. A valid prescription from a licensed prescriber is sufficient documentation. Letters of Medical Necessity are typically required for items in a gray area (certain medical devices, some supplements). Tirosint's prescription-only status resolves eligibility without an LMN.
How do I get Tirosint cheaper without insurance?
Three options exist for uninsured patients: (1) Apply for IBSA's Patient Assistance Program, which provides Tirosint free or at reduced cost for qualifying low-income patients. (2) Use GoodRx or similar coupon platforms at participating pharmacies for cash-pay discounts. (3) Fund an HSA (available with HDHPs) and use pre-tax dollars, effectively reducing the real cost by your marginal tax rate.
Can I use the IBSA savings card and my HSA/FSA together?
Generally no. Manufacturer co-pay cards are considered third-party payments. Most HSA/FSA administrators require that you pay the expense yourself for reimbursement. If the savings card covers part of the cost and you pay the remainder out of pocket, the out-of-pocket portion may be reimbursable. Confirm the specific terms with your HSA custodian and your plan's FSA administrator before attempting to stack these benefits.
Is Tirosint-SOL (liquid) also HSA/FSA eligible?
Yes. Tirosint-SOL is FDA-approved under NDA 206977 and is prescribed for hypothyroidism. It carries the same qualified medical expense status as the gel-cap formulation. The same documentation rules apply: keep your itemized receipt and the prescription label.
What if my insurance denies Tirosint and I pay cash, can I still use HSA funds?
Yes. There is no requirement that insurance cover a drug for it to be HSA or FSA eligible. The eligibility test is whether it is an FDA-approved prescription drug for a diagnosed condition, which Tirosint meets. Paying cash and submitting to your HSA for reimbursement is fully permissible.
How long can I wait to reimburse myself from my HSA for a Tirosint purchase?
There is no IRS-imposed deadline for HSA reimbursements, as long as the expense occurred after the HSA was established and the account was funded at the time of the expense. You could pay for Tirosint in 2026 and reimburse yourself in 2030. Keep the receipt. FSAs have strict plan-year deadlines and do not offer this flexibility.
Does switching from generic levothyroxine to Tirosint require TSH retesting?
Yes. The American Thyroid Association recommends TSH measurement 4 to 8 weeks after any formulation change. Bioavailability differences between tablet and gel-cap forms can alter effective dose. Your prescriber should order a TSH recheck 6 weeks after the switch. Any dose adjustment that follows may also change your monthly supply quantity and cost.
Is there a generic version of Tirosint gel caps I could use instead to save money?
No AB-rated generic gel-cap levothyroxine product existed as of early 2026. Generic levothyroxine tablets (25 mcg to 300 mcg) are widely available at very low cost, but they are not bioequivalent to the gel-cap formulation for patients with absorption issues. If a generic gel cap becomes approved and AB-rated, your pharmacist can substitute it; until then, Tirosint remains the only FDA-approved levothyroxine gel cap.
Can I use an LP-FSA (Limited-Purpose FSA) for Tirosint?
An LP-FSA is restricted to dental and vision expenses by default. However, if your employer's plan includes a post-deductible conversion feature, the LP-FSA may cover prescriptions including Tirosint once you have met your HDHP deductible. Review your Summary Plan Description or ask your HR benefits administrator for the specific trigger and conversion rules.
What documentation do I need to keep for an IRS audit of my HSA?
Keep itemized pharmacy receipts (showing drug name, date, patient name, and amount paid), the prescription label or printout, and your HSA custodian's reimbursement confirmation. The IRS can audit HSA distributions for up to three years after the tax return filing date. Digital copies stored securely are acceptable; paper originals are not required.

References

  1. U.S. Food and Drug Administration. Tirosint (levothyroxine sodium) capsules, NDA 201831 prescribing information. https://www.accessdata.fda.gov/drugsatfda_docs/label/2020/201831s016lbl.pdf

  2. Fallahi P, Ferrari SM, Ruffilli I, et al. Bioequivalence and pharmacokinetics of levothyroxine soft-gel capsule vs. Tablet formulations. Thyroid. 2013;23(8):1014-1020. https://pubmed.ncbi.nlm.nih.gov/23544849/

  3. Internal Revenue Service. Publication 502: Medical and Dental Expenses. 2025 edition. https://www.irs.gov/publications/p502

  4. American Diabetes Association. Standards of Medical Care in Diabetes, 2024. Diabetes Care. 2024;47(Suppl 1). https://diabetesjournals.org/care/issue/47/Supplement_1

  5. U.S. Food and Drug Administration. FDA Drug Safety Communication: Dangers of compounding thyroid medications. FDA.gov. https://www.fda.gov/drugs/drug-safety-and-availability/fdas-role-regulating-compounded-drug-products

  6. Jonklaas J, Bianco AC, Bauer AJ, et al. Guidelines for the treatment of hypothyroidism: prepared by the American Thyroid Association Task Force on Thyroid Hormone Replacement. Thyroid. 2014;24(12):1670-1751. https://pubmed.ncbi.nlm.nih.gov/25266247/

  7. Centanni M, Gargano L, Canettieri G, et al. Thyroxine in goiter, Helicobacter pylori infection, and chronic gastritis. N Engl J Med. 2006;354(17):1787-1795. https://pubmed.ncbi.nlm.nih.gov/16641395/

  8. Virili C, Bassotti G, Santaguida MG, et al. Atypical celiac disease as cause of increased need for thyroxine: a systematic study. J Clin Endocrinol Metab. 2012;97(3):E419-E422. https://pubmed.ncbi.nlm.nih.gov/22238404/

  9. Jonklaas J, Bianco AC, Bauer AJ, et al. Guidelines for the treatment of hypothyroidism. Thyroid. 2014;24(12):1670-1751. https://pubmed.ncbi.nlm.nih.gov/25266247/

  10. Benvenga S, Vita R, Di Bari F, Venuti R, Santaguida MG, Centanni M. Do not forget the thyroid when considering changes in requirements for levothyroxine. Thyroid. 2020;30(7):986-989. https://pubmed.ncbi.nlm.nih.gov/32070217/

  11. U.S. Food and Drug Administration. Tirosint-SOL (levothyroxine sodium) oral solution, NDA 206977. https://www.accessdata.fda.gov/drugsatfda_docs/label/2016/206977lbl.pdf

  12. Duntas LH, Jonklaas J. Levothyroxine dose adjustment to optimise therapy throughout a patient's lifetime. Adv Ther. 2019;36(Suppl 2):30-46. https://pubmed.ncbi.nlm.nih.gov/31485955/

  13. Pirola I, Formenti AM, Gandossi E, et al. Oral liquid levothyroxine treatment at breakfast: a mistake? Eur Thyroid J. 2013;2(3):180-183. https://pubmed.ncbi.nlm.nih.gov/24783055/

  14. Walker JN, Bhakeney A, Bhakeney LE. Levothyroxine absorption in gastrointestinal conditions. Endocr Pract. 2020;26(Suppl 1):14-20. https://pubmed.ncbi.nlm.nih.gov/32069152/

  15. Centers for Medicare and Medicaid Services. Health Savings Accounts (HSA) and Health Reimbursement Arrangements (HRA). CMS.gov. https://www.cms.gov/CCIIO/Programs-and-Initiatives/Health-Insurance-Market-Reforms/Health-Savings-Accounts

  16. Santaguida MG, Virili C, Del Duca SC, et al. Thyroxine softgel capsule in patients with gastric-related T4 malabsorption. Endocrine. 2015;49(1):51-57. https://pubmed.ncbi.nlm.nih.gov/25300285/

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