Econ Data License

1. What the Artifact is

Atlas (the "Artifact") is a set of figures about money moving into and out of organ recovery and transplant, fiscal years 2019 through 2025, read out of public federal filings:

(a) the organ procurement organization cost report, form CMS-216-94, as published by CMS in the Healthcare Cost Report Information System (HCRIS); (b) the transplant hospital cost report, form CMS-2552-10, from the same system; (c) the IRS Form 990 e-file return, including Schedule J and Schedule R; (d) HRSA donation service area data, which the Artifact uses only to establish which organization a provider number belongs to and where it serves. No figure in the Artifact is derived from geography.

2460 Health Tech normalizes, decodes and cites those filings. Our work is the reading, not the reporting. Every figure carries a citation naming the filing, and the worksheet, line and column, or the Form 990 part and line, it was read from, together with the fiscal period and the filer's own label for that line. Each release is identified by a release tag and by a sha256 hash computed over its values. A published release is never edited. A correction is a new release with a new hash.

2. What we claim, and what we do not

The filings are public records, and almost nothing in the Artifact is ours to license.

Facts are not copyrightable. Feist Publications, Inc. v. Rural Telephone Service Co., 499 U.S. 340, 344 to 345 (1991). A dollar amount an organization reported on a line of a federal form is a fact. The Copyright Office's own regulation reaches the rest of it. Blank forms designed for recording information are not subject to copyright, 37 C.F.R. 202.1(c), and that is what CMS-216-94, CMS-2552-10 and Form 990 are. Words and short phrases are not subject to copyright, 37 C.F.R. 202.1(a), and that is what a worksheet label is. Works consisting entirely of information that is common property with no original authorship, "such as ... lists or tables taken from public documents or other common sources," are not subject to copyright, 37 C.F.R. 202.1(d). And copyright in a compilation extends only to the material the compiler contributed, not to the preexisting material. 17 U.S.C. 103(b). The blank forms themselves, and the agencies' own publications, are in addition works of the United States Government and cannot be copyrighted. 17 U.S.C. 105.

One correction to a thing people often assume. A Medicare cost report or a Form 990 is prepared by the filing organization, not by a federal employee, so the filing itself is not a "work of the United States Government" within 17 U.S.C. 101 and 105. It is a private document that federal law makes public. What makes you free to use it is the law of facts and public records set out above, and, for a Form 990, 26 U.S.C. 6104. Not 17 U.S.C. 105.

What we license, to the extent anything in it is protected at all, is our compilation: the selection of what to read, the normalization, the decoding of the forms, the labeling, and the citation layer. We claim nothing in the filings and nothing in the facts they report. A compilation copyright would not let us stop you extracting the public data inside it even if we wanted to. Assessment Technologies of WI, LLC v. WIREdata, Inc., 350 F.3d 640 (7th Cir. 2003). We do not want to.

Two things are not ours and are not licensed here. First, where a filer wrote original text of their own into a filing, such as a narrative in Schedule J Part III, any rights in that text belong to the filer. We reproduce it as part of a public filing and we license nothing of the filer's. Second, "Meira," "MeiraPay" and the associated logos are trademarks of 2460 Health Tech and are not licensed by this document. Naming us in attribution, which is what Section 4 asks you to do, is not trademark use we object to.

3. The license grant

The Artifact, every figure, label and citation in it, and every release of it, is licensed under the Creative Commons Attribution 4.0 International license (CC BY 4.0), at https://creativecommons.org/licenses/by/4.0/legalcode. You may copy, redistribute, adapt and build on it, for any purpose including commercially, provided you attribute it as Section 4 describes and indicate what you changed.

The grant covers whatever rights we have, and no more. Where the material is not protected, no permission from us is needed and none is implied by this document. Nothing here should be read as a claim that you need our permission to use a federal filing. Where sui generis database rights are recognized, CC BY 4.0 Section 4 applies and the grant reaches them.

The same license applies whether you obtained the Artifact as a free download or through the API. This document covers the data. API keys are covered by the Econ API Purchase Terms.

4. Attribution

We want this used, including by people working to a deadline in a medium with no room for a footnote. CC BY 4.0 Section 3(a)(2) lets you satisfy its conditions "in any reasonable manner based on the medium, means, and context in which You Share the Licensed Material." Here is what we consider reasonable, so that nobody has to guess.

The minimum, and it is enough anywhere, including a chart credit, a broadcast super or a footnote:

Meira Atlas (2460 Health Tech), CC BY 4.0, from CMS and IRS filings.

Where you can carry a link, add the release and the link, because that is what makes the figure checkable:

Source: Meira Atlas, release <tag>, 2460 Health Tech, Inc., CC BY 4.0, derived from CMS cost reports (CMS-216-94 and CMS-2552-10) and IRS Form 990 filings. https://atlas.meira.life/releases

In a data file, a methodology note, or anywhere the full line fits, use the line that ships as the first row of every CSV and in the API response. It adds the sha256 hash of the release. You are never required to print that hash in a visible credit. Its job is to let a reader verify a copy against the release, and it is reachable without a key at https://atlas.meira.life/api/econ/v1/releases/<tag>.

Say if you changed the figures. Recomputing, reclassifying, combining years or filers, and deriving a new measure are changes. Reformatting, rounding for display, translating a label, and charting a figure as published are not.

Two things you must not do, and the second is not our rule but CMS's. Do not present the Artifact, or anything derived from it, as CMS data, HRSA data or IRS data. Do not attribute a conclusion drawn from it to CMS, HRSA or the IRS. CMS states this itself on its cost report page: CMS "is not responsible for data that is misrepresented, misinterpreted or altered in any way," and "derived conclusions and analysis generated from this data are not to be considered attributable to CMS or HCRIS." The Artifact is altered data in exactly that sense. It is normalized, decoded and relabeled by us, and the citation on every figure is there so a reader can go back to the unaltered cell.

Attribution is a condition of this license where the material is protected. Where it is not protected, attribution is what we ask rather than what we can require, and we ask it for the same reason you would: a figure with its source attached is worth more than one without.

5. What we represent, and what we do not

We make one representation, and it is the whole product claim.

Every figure in a published release names the cell it was read from. We represent that the value we publish is the value in that cell, after the normalization set out on the About page at https://atlas.meira.life/about, which is the method, and that a published release does not change after publication. If a figure and its cited cell disagree, that is our defect. Write to hello@meira.life and we will correct it in the next release, as a new release with a new hash rather than as an edit to the old one. Corrections are announced by email to API key holders and listed on the releases page, which anyone can read without a key.

We do not represent that a filer filed correctly, completely or on time, that a cost report has been audited or settled, that CMS, HRSA or the IRS published a complete or current copy of any filing, that figures are comparable between filers, between fiscal years or between forms, or that any figure supports any conclusion about any organization. The filing is the authority. If our figure and the filing disagree, the filing controls. Before you make a public claim on a figure, open the cited cell.

2460 Health Tech is not a government body and the Artifact is not a government publication. CMS, HRSA and the IRS have not reviewed, approved or endorsed it.

Apart from the representation in this Section, the Artifact is provided as is. Section 5 of CC BY 4.0 disclaims the other warranties and limits liability, and it applies here unchanged.

6. Personal information in the filings

The Artifact reproduces the names, titles and reported compensation of officers, directors, trustees, key employees and highest-compensated employees exactly as the filing organization reported them on Form 990 Part VII and Schedule J. It reproduces nothing about any individual from any other source.

Those returns are open to public inspection by federal law, 26 U.S.C. 6104(b) and (d), and the IRS publishes them itself.

We do not reproduce Schedule B. The names and addresses of contributors to an organization that is not a private foundation and not a section 527 political organization are not part of what federal law opens to public inspection. 26 U.S.C. 6104(b) and 6104(d)(3)(A). They are not in the Artifact and they will not be.

Under the California Consumer Privacy Act, "personal information" does not include publicly available information, which the statute defines to include "information that is lawfully made available from federal, state, or local government records." Cal. Civ. Code 1798.140(v)(2). The Form 990 lines in the Artifact are that. Other states draw the line differently, and we do not represent that every privacy statute everywhere reaches the same result.

We reproduce these lines as filed and do not edit them. If a person believes a filing misstates their compensation, the correction belongs with the filing organization or with the IRS, because the Artifact records what was filed, and correcting the Artifact away from the filing would break the only thing it is for. If we transcribed a line wrongly, that is ours, and Section 5 applies.

The Artifact is not designed to carry, and is not intended to carry, any patient, donor, recipient or referral information, and none has been found in it. The filings it reads are organization-level financial returns and do not call for information of that kind. The fields where a filer writes their own text, such as worksheet write-in labels, are read by a person before a release is published. If you find anything of that kind in a release, write to hello@meira.life and we will correct it in the next release.

7. Access, rate limits and pinning

Any published release can be downloaded in full for free, with no key and no account, from the endpoints listed at https://atlas.meira.life/api/econ/v1. The free download is the whole release, and it is bounded per network address rather than per key.

The keyed endpoints, which add filtering, paging, CSV export, roster sections and release-to-release differences, need an API key under the Econ API Purchase Terms.

Pin a release. Every figure address takes a release tag or a values hash, and a request without one returns the current release and names it in the response. A figure you cited under a tag is the same figure a year later, because a published release is never edited. The values hash lets anyone check a copy of a release against the release itself.

8. Versions and contact

This license is versioned, and each version is identified in its heading. A release is published under the version of this license current at the time of publication, and that version continues to govern that release. The text of every version stays published.

Questions, corrections and attribution queries: hello@meira.life, or https://atlas.meira.life/contact. 2460 Health Tech, Inc., 455 Market Street, Suite 1940, San Francisco, CA 94105.