Summary Plan Description for Achieva Section 125 and FSA Plan

SUMMARY PLAN DESCRIPTION For ACHIEVA SECTION 125 AND FSA PLAN Amended and Restated as of July 1, 2024, unless otherwise noted The Plan Sponsor reserves the right to amend this Plan, in its sole discretion, at any time without the consent of any employee, former employee, or participant. The benefits provided under the Plan are not guaranteed benefits for covered persons or for their dependents. The Plan Sponsor reserves the right, in its sole discretion, to terminate the Plan or any Plan feature or component at any time and for any reason without liability. The terms "you" and "your" as used in this document refer to an individual who is otherwise eligible to participate in the Plan. Receipt of this document does not guarantee that the recipient is in fact eligible to participate in the Plan or any Plan feature or component.

3 5 5 5 6 6 6 6 6 6 6 6 7 7 9 9 9 9 9 9 10 10 10 14 14 14 14 14 15 15 15 15 15 15 15 15 15 16 16 16 16 16 16 18 18 18 18 19 19 19 20 21 21 23 23 Table of Contents Table of Contents ELIGIBILITY When Will I Become Eligible To Participate In This Plan? What Must I Do To Enroll In The Plan? OPERATION How Does The Plan Operate? Who Is a Dependent? CONTRIBUTIONS How Is My Compensation Measured Under The Plan? What Contributions Are Made To The Plan? What Happens To Contributions That Are Made To The Plan? When Must I Decide What Coverage I Want? When Is The Election Period For The Plan? May I Change My Elections During The Plan Year? May I Make New Elections In Future Plan Years? BENEFITS What Benefits Are Available Under The Plan? HEALTH CARE FLEXIBLE SPENDING ACCOUNT PROGRAM What Is A Health Care Flexible Spending Account? What Health Care Expenses Can Be Reimbursed? How Does The Health Care Flexible Spending Account Work? Is My Health Information Protected? What If My Coverage Under The Health Care Flexible Spending Account Program Is Terminated? DEPENDENT CARE ASSISTANCE ACCOUNT What Is A Dependent Care Assistance Account? Who Is An Eligible Dependent? What Limits Apply? How Does The Dependent Care Assistance Account Work? What Is The Dependent Care Tax Credit PREMIUM DEDUCTIONS How Are Employee Premiums For Health And Welfare Plans Paid? TERMINATION OF EMPLOYMENT What Happens If My Employment is Terminated During the Plan Year? HIGHLY COMPENSATED AND KEY EMPLOYEES Do Limitations Apply To Those Who Are Highly Compensated? GENERAL INFORMATION ABOUT THE PLAN General Plan Information Employer Information Plan Administrator Information Service Of Legal Process Type Of Administration ADDITIONAL PLAN INFORMATION ERISA Rights And Protections Filing A Claim Notification Of Your Claim Claim Denial Appealing A Denied Claim HEALTH CARE CLAIM PROCEDURES Health Care Claim Definition Filing A Health Care Claim Notification Of Your Health Care Claim Health Care Claim Denial Appealing A Denied Health Care Claim APPENDIX A Qualifying Health Care Expenses

25 Schedule A - Participating Employers

ACHIEVA SECTION 125 AND FSA PLAN SUMMARY PLAN DESCRIPTION INTRODUCTION We are pleased to announce that we have established a Flexible Benefits Plan (the "Plan") under which you may choose to redirect a portion of your wages to pay for your share of the costs of available health and welfare plans that we sponsor and/or set aside money to pay for unreimbursed medical expenses (Health Care Flexible Spending Account) and/or dependent care expenses (Dependent Care Assistance Account), all with pre-tax dollars. This means that you will pay less in taxes each year. Read this Summary Plan Description carefully so that you understand the provisions of the Plan and the benefits you will receive. We want you to be fully informed of the benefits available to you under the Plan both before you enroll and while you are a participant. You should direct any questions you have to the Plan Administrator. There are Plan documents available upon request for your review. IF THERE IS A CONFLICT BETWEEN THIS SUMMARY PLAN DESCRIPTION AND THE PLAN DOCUMENTS, THE PLAN DOCUMENTS WILL PREVAIL. IF THERE IS A CONFLICT BETWEEN AN INSURANCE CONTRACT WHICH FUNDS BENEFITS AND EITHER THE PLAN DOCUMENTS OR THIS SUMMARY PLAN DESCRIPTION, THE INSURANCE CONTRACT WILL PREVAIL. I. ELIGIBILITY 1.1 When Will I Become Eligible To Participate In This Plan? You will become eligible to participate in this Plan when you become eligible to participate, and you enroll, in any of the Plan Sponsor's health and welfare plans available under this Plan, the Health Care Flexible Spending Account Program and/or the Dependent Care Assistance Account Program. For eligibility rules concerning the Plan Sponsor's health and welfare plans for which you pay a premium, please see the summary plan description or plan document for each. You should ask the Plan Administrator for copies of such documents if you need them. If you are a regular full-time employee who is regularly scheduled to work for the Plan Sponsor at least 30 hours per week, you will be eligible to participate in the Health Care Flexible Spending Account Program and/or the Dependent Care Assistance Account Program as of the first day of the month following 60 days. Please note that if you are initially classified as an independent contractor (or any other non-employee designation) by your Employer and are subsequently determined to be a common law employee for any purpose, including without limitation, for wage, labor or tax purposes by either the Internal Revenue Service, Department of Labor or any other Federal or state agency, administrative body or court, you will still be ineligible for participation in the Plan for the period during which you were a non-employee. Unless otherwise noted herein, an employee shall not include any self-employed individual, partner in a partnership, and more-than-2% shareholder in a Subchapter S corporation. 1.2 What Must I Do To Enroll In The Plan? If you are a new employee, you must complete an enrollment form/salary reduction agreement by the first day of the first pay period for the benefit(s) you elect that are part of this plan (as communicated in your enrollment materials). If you are an existing employee, once you enroll in any of the qualified benefits that are part of this plan, then you must complete an election form prior to the beginning of each Plan Year or you will be deemed to have elected to receive the full amount of your compensation in cash. However, in either case, if you do not timely complete an enrollment form/salary reduction agreement, you will be deemed to have elected to receive the full amount of your compensation in cash. If you are newly eligible for the Plan and elect to make contributions to the Health Care Flexible Benefit Plan and/or Dependent Care Flexible Benefit Plan you must complete an enrollment form/salary reduction agreement to participate within the time periods specified in Article III of this SPD. You must complete an enrollment form/salary reduction agreement each Plan Year to participate in the Health Care Flexible Benefit Plan and/or Dependent Care Page 4

Flexible Benefit Plan. II. OPERATION 2.1 How Does The Plan Operate? Before the start of each Plan Year (as defined below), you may elect to have a portion of your salary or wages deducted on a pre-tax basis, and allocate your salary reductions to pay for the cost of the employee portion of the premiums due under any of the health and welfare plans available under the Plan, and fund the Health Care Flexible Spending Account and/or Dependent Care Assistance Account. 2.2 Who Is a Dependent? For purposes of the Health Care Flexible Spending Account Program, or other Qualified Benefit Plans which provides accident or health coverage for which a premium is required, a "dependent" is your child (as defined in Code Section 152(f)(1)) who has not attained age 27 by the end of the calendar year, and any individual who is a tax dependent of yours as defined in Code Section 152 (determined without regard to Sections 152(b)(1), (b)(2) and (d)(1) (B)). For purposes of the Dependent Care Assistance Account Program, please see Section 6.2 below for more information about who is an "eligible dependent" for reimbursement of dependent care expenses. NOTE THAT THE HEALTH AND WELFARE PLANS MAY HAVE DIFFERENT DEFINITIONS OF "DEPENDENT" FOR PURPOSES OF COVERAGE AND ELIGIBILITY FOR BENEFITS. AS A RESULT, FOR TAX PURPOSES, IF YOU ARE COVERING AN ELIGIBLE DEPENDENT UNDER A HEALTH AND WELFARE PLAN WHO DOES NOT MEET THE DEFINITIONS ABOVE, THEN THE BENEFITS FOR SUCH DEPENDENTS MAY BE TAXABLE TO YOU. NOTE: Please see the Plan Administrator if you have any questions about the "dependent" status of any individual in your family and/or whether or not coverage for certain dependents may be taxable to you. III. CONTRIBUTIONS 3.1 How Is My Compensation Measured Under The Plan? Compensation under the Plan means the total cash amount that is paid to you each year. 3.2 What Contributions Are Made To The Plan? Contributions to the Plan consist of contributions made by your election to reduce your salary or wages by a certain amount that represents your share of cost of the underlying health and welfare benefits in which you are enrolled, and for the funds you elect to contribute to fund a Health Care Flexible Spending Account and/or Dependent Care Assistance Account. NOTE THAT THE AMOUNT OF THE EMPLOYER CONTRIBUTIONS MADE TO THE PLAN ON YOUR BEHALF ARE WITHIN THE SOLE DISCRETION OF THE EMPLOYER, AND YOU HAVE NO CONTRACTUAL RIGHT TO ANY EMPLOYER CONTRIBUTIONS. YOUR EMPLOYER MAY INCREASE, DECREASE OR ELIMINATE SUCH CONTRIBUTIONS AT ANY TIME WITHIN ITS SOLE DISCRETION. 3.3 What Happens To Contributions That Are Made To The Plan? All contributions to the Plan, including your salary or wage reductions, may be used to pay for benefits under the Plan in any way that you want (as long as such benefits are covered under the Plan). By your election, contributions that you defer are set aside into your Health Care Flexible Spending Account and/or Dependent Care Assistance Account only to be reimbursed for eligible expenses, and/or used to pay the cost of the employee portion of applicable premiums in the health and welfare plans you choose. 3.4 When Must I Decide What Coverage I Want? Except as described in Section 3.6 below, you may elect benefits under the Plan only during the "election Page 5

period." 3.5 When Is The Election Period For The Plan? If you are a newly eligible Employee, the election period for the Plan will be the thirty (30) day period prior to the date you become eligible to participate in the Plan. See the Plan Administrator if you have any questions about the dates you become eligible to participate in the Plan. For existing employees, the Plan Administrator will establish an election period for a reasonable period of time prior to the beginning of each Plan Year, and such election period will be communicated to you in advance. 3.6 May I Change My Elections During The Plan Year? Generally, no. You cannot change the elections you have made after the beginning of the Plan Year. However, you are permitted to change certain elections if you experience an IRS defined "change in status" and/or other special events as described below. Examples of status changes include these events: (i) marriage; (ii) divorce, legal separation or annulment; (iii) death of your spouse or dependent child; (iv) birth, adoption or placement for adoption of a child; (v) termination of the employment of your spouse or dependent child; (vi) commencement of the employment of your spouse or dependent child; (vii) your or your spouse's or dependent child's commencement or return from an unpaid leave of absence from employment; (viii) adjustment to your or your spouse's or dependent child's work schedule, such as a switch between part- time and full-time work, a strike, a lockout or an increase or reduction in hours of employment, that causes a loss of coverage; (ix) a change in your or your spouse's or dependent child's worksite or residence that causes a loss of current coverage eligibility; (x) adjustments in dependent status through satisfying or ceasing to satisfy the age, student status or other requirements to qualify as a dependent under the Plan; (xi) significant change in your or your spouse's health coverage attributable to the spouse's employment; and (xii) leave of absence under the Family and Medical Leave Act. Your election may also be changed if one of these special events occurs: (i) the issuance of a judgment, decree or order that requires accident or health coverage for your dependent child. (ii) your or your spouse's or dependent child's entitlement to Medicare or Medicaid that causes a loss of coverage. (iii) your or your spouse's or dependent child's loss of eligibility for Medicare or Medicaid. (iv) a "significant" increase in the cost of any benefit under the Plan; provided that for the Dependent Care Assistance Account program, the increase in cost is imposed by a dependent care giver who is not your relative. No election change may be made as to the Health Care FSA Program on account of a significant cost change. *Note: If the cost of a health and welfare plan increases or decreases during the Plan Year, this Plan may, on a reasonable and consistent basis, automatically change your premium contributions in response to the change in cost. (v) "significant" improvement in coverage, such as the addition of new benefit plan, or significant improvement Page 6

in coverage offered under an existing benefit plan. You may cancel your election and receive coverage under the new or improved benefit option. No election change may be made as to the Health Care FSA Program on account of a significant improvement in coverage. (vi) elimination or "significant" cutback in coverage provided by an insurance company or other third party. You may cancel your election and receive coverage under a similar plan, provided both plans agree to make the change. No election change may be made as to the Health Care FSA Program on account of a significant cutback in coverage. (vii) your failure to make the required premium payment. Your election will be canceled but you will not be able to make a new election for the rest of the Plan Year. (viii) your separation from service. If you terminate employment, you may cancel your election for any remaining period of coverage. (ix) your loss of group health coverage sponsored by a governmental or educational institution. No election change may be made as to the Health Care FSA Program and the Dependent Care FSA Program loss of such coverage. (x) your spouse or dependent makes an election change under a plan maintained by his or her employer that has a different period of coverage than this Plan. No election change may be made as to the Health Care FSA Program for this reason. (xi) your enrollment and/or or a related individuals' enrollment in Marketplace coverage. If you and/or a related individual enroll or intend to enroll in Marketplace coverage during the Marketplace's annual open enrollment period or during a special enrollment period, the Administrator may permit you to cancel your election for any remaining period of coverage, provided that you and/or the related individual or related individuals who cease coverage due to the revocation enroll in a Marketplace plan effective immediately following the revocation. If only a related individual or related individuals enroll or intend to enroll in Marketplace coverage, you will be transitioned to self-only coverage (or family coverage including one or more already-covered related individuals) under the Employer's health benefits. Coverage may only be terminated for those covered individuals who are enrolling or intend to enroll in Marketplace coverage during open enrollment or pursuant to a Marketplace special enrollment period. No change is permitted with regard to non-health benefits including the Health Care Flexible Spending Account Program and Dependent Care Flexible Spending Account Program available under the Plan. (xii) your permanent reduction of hours. If you were reasonably expected to average 30 hours of service or more per week and experience an employment status change such that you are no longer reasonably expected to average 30 hours of service or more per week, the Administrator may permit you to cancel your election for any remaining period of coverage, provided that you (and any related individuals who cease coverage due to the revocation) enroll or intend to enroll in another plan no later than the first day of the second full month following the revocation. No change is permitted with regard to non-health benefits including the Health Care Flexible Spending Account Program and Dependent Care Flexible Spending Account Program available under the Plan. If you have a status change and you want to cancel or modify your election for a Plan Year, you must file a written application with the Plan Administrator within 30 days of the event, or within 60 days in the case of a special enrollment right due to the loss of eligibility for Medicaid or state children's health insurance program coverage, or eligibility for a state premium assistance subsidy from a Medicaid plan or through a state children's health insurance program with respect to coverage under the group health plan. Keep in mind that any change to your election must be consistent with your status change. The Plan Administrator will consider your application and inform you of the decision. Elections made under this Plan automatically terminate on the date on which you cease to be a participant in the Plan, although coverage or benefits under the Medical Plans and/or the Health Care Flexible Spending Account Program may continue if and to the extent provided by such plan or as required by law. In the event you become a participant again within 30 days of the date you stopped being a participant and before the end of the same Plan Year, the elections you previously had in effect shall automatically be reinstated for the balance of the Plan Year. If you become a participant 30 days or more after the date you stopped being a participant and before the end of the Same Plan year, you may make new elections; however your elections for the Health Care Flexible Spending Account and Dependent Care Flexible Spending Account may not exceed the maximum annual contributions as set forth Sections 5.1 and 6.1 herein and applicable law. Page 7

3.7 May I Make New Elections In Future Plan Years? Yes, you may. If you want to participate in the Health Care Flexible Spending Account Program and/or the Dependent Care Assistance Account Program for an upcoming Plan Year, you must complete a new enrollment form/salary reduction agreement in order to participate for that Plan Year, regardless of whether or not you are making changes in your elections. Further, each year you will have the opportunity to renew your elections to participate in the Plan with respect to the pre-tax premiums for the underlying health and welfare benefits in the Plan that you choose for the next Plan Year. IV. BENEFITS 4.1 What Benefits Are Available Under The Plan? Under the Plan, you may choose to receive your entire compensation in cash or use a portion to pay for any of the nontaxable benefits available under the Plan. The nontaxable benefits under the Plan include: (i) Pre-tax premium contributions provided under the Plan Sponsor's health and welfare plans available under this Plan, as designated and announced by the Plan Sponsor from time to time; (ii) The Plan Sponsor's Health Care Flexible Spending Account program, the details of which are described below; (iii) The Plan Sponsor's Dependent Care Assistance Account program, the details of which are described below; In the case of insured benefits, certain limits may apply on the amount of coverage that we obtain on your behalf. For example, it is possible, though unlikely, that even if you are a participant in the Plan, you might fail to qualify for coverage under the insured benefits offered under the Plan. Here, it is the insurance contracts, and not the terms of the Plan, which will dictate. The Plan Sponsor may terminate or modify Plan benefits at any time, subject to the provisions of any insurance contracts. We will not be liable to you if an insurance company fails to provide any of the benefits described above, even if the failure to provide benefits is due to our gross negligence (for example, if we fail to enroll you or pay premiums). In the case of health benefits, you may have a right by law to continue your benefits that would otherwise terminate when (i) you leave employment, (ii) you are no longer eligible under the terms of any group health plan or insurance policy, or (iii) when insurance coverage terminates. Any benefits to be provided by insurance will be provided only after you have furnished the Plan Administrator with the necessary enrollment forms. V. HEALTH CARE FLEXIBLE SPENDING ACCOUNT PROGRAM 5.1 What Is A Health Care Flexible Spending Account? The Health Care Flexible Spending Account (HFSA), is intended to pay for health care expenses not covered by your group health plans and/or deductibles and other out-of-pocket expenses associated with your group health plans. The HFSA is a tax savings vehicle which enables you to take money pre-tax from your salary to pay for certain unreimbursed medical expenses. Then, as you incur eligible expenses, you are reimbursed from your account. The maximum amount you can elect to contribute to your HFSA is limited to the statutory amount under Section 125(i)(2) of the Code in effect on January 1st of the same calendar year in which the Plan Year begins, as indexed for cost of living increases for any Plan Year beginning with or within such calendar year, which has been communicated to you by the Plan Sponsor separately. The maximum amount is available to you as of the first day of the Plan Year. These limits will be reviewed annually and adjusted as experience indicates. The minimum amount you can elect to contribute your Health Care FSA is for the Plan Year is $120. 5.2 What Health Care Expenses Can Be Reimbursed? Only "qualifying health care expenses" can be reimbursed. To be eligible an expense must: Page 8

(i) be for medical care incurred within the Plan Year; (ii) not be reimbursable from another source; (iii) be incurred by you or your spouse or dependents; and (iv) not be claimed as a tax deduction. A more detailed description of qualifying health care expenses is set forth in Appendix A to this Summary Plan Description. 5.3 How Does The Health Care Flexible Spending Account Work? You elect to participate in the HFSA by providing a source of pre-tax funds to reimburse yourself for your qualifying health care expenses by entering into an election form/salary reduction agreement with your Employer. Under that agreement, you agree to a salary reduction to fund the HFSA instead of receiving a corresponding amount of your regular pay. As you incur qualifying health care expenses, you may obtain reimbursement by submitting a claim form to the Plan Administrator, or if applicable, a third-party administrator designated by the Plan Administrator from time to time. (See Section 12.2 of this Summary Plan Description.) The Plan Administrator offers a debit card program for the reimbursement of qualifying health care expenses. Therefore, you may also obtain reimbursement by paying the provider directly for your qualifying health care expenses with a debit card that is provided to you by the Plan Administrator, or if applicable, a third-party administrator designated by the Plan Administrator from time to time. The debit card will be funded with the amount of funds in your account, and the account balance will be reduced in amounts equal to your reimbursed health care expenses. You are still required to meet any applicable substantiation requirements if you use a debit card, as communicated by the Plan Administrator. If any expenses reimbursed by your debit card are subsequently determined to be non-qualifying health care expenses, the Plan Administrator may use methods permitted under applicable law or the Plan to recover such funds. If the provider does not accept payment with your debit card, then you should submit a paper claim form to the Plan Administrator, or if applicable, a third- party administrator designated by the Plan Administrator from time to time. You should contact the Plan Administrator if you need a paper claim form. EMPLOYEES WHO FAIL TO USE (SPEND) 100% OF THE AMOUNT CREDITED TO THE HFSA FOR A CERTAIN PLAN YEAR WILL FORFEIT THE UNUSED PORTION AT THE END OF THE PLAN YEAR. 5.4 Is My Health Information Protected? This Plan will operate in accordance with the Health Insurance Portability and Accountability Act of 1996 (HIPAA), including, but not limited to, the privacy and security regulations with respect to protected health information to the fullest extent required by law. A description of the HIPAA privacy rights of each person covered under the Plan is contained in the Privacy Notice which has been provided to you. If you need a copy of the Privacy Notice or if you have any complaints, questions or concerns about anything addressed in the Privacy Notice, please see your Human Resources representative. 5.5 What If My Coverage Under The Health Care Flexible Spending Account Program Is Terminated? Introduction The right to COBRA continuation coverage was created by a Federal law, the Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA). COBRA continuation coverage can become available to you and to other members of your family who are covered under the Plan when you would otherwise lose your group health coverage (including coverage under the Health Care Flexible Spending Account program). The following generally explains COBRA continuation coverage, when it may become available to you and your family, and what you need to do to protect the right to receive it. This notice gives only a summary of your COBRA continuation coverage rights. For more information about your COBRA rights and obligations under the Plan and under Federal law, you should ask the Plan Administrator The Plan Administrator is responsible for administering COBRA continuation coverage, but the Plan Administrator may delegate its administrative duties to a third-party administrator from time to time. The Plan Page 9

Administrator has delegated authority for administering COBRA continuation coverage to the following COBRA Administrator: UPMC Benefit Management Services U.S. Steel Tower, 600 Grant Street Pittsburgh, PA 15219 (844) 220-4785 COBRA Continuation Coverage COBRA continuation coverage is a continuation of group health plan coverage when coverage would otherwise end because of a life event known as a "qualifying event." COBRA applies to each group health plan under the Plan. Specific qualifying events are listed later. COBRA continuation coverage must be offered to each person who is a "qualified beneficiary." A qualified beneficiary is someone who will lose coverage under the Plan because of a qualifying event. Depending on the type of qualifying event, employees, spouses of employees, and dependent children of employees may be qualified beneficiaries. Qualified beneficiaries who elect COBRA continuation coverage must pay for COBRA continuation coverage. If you are an employee, you will become a qualified beneficiary if you will lose your coverage because either one of the following qualifying events happens: (i) Your hours of employment are reduced; or (ii) Your employment ends for any reason other than your gross misconduct. If you are the spouse of an employee, you will become a qualified beneficiary if you will lose your coverage because any of the following qualifying events happens: (i) Your spouse dies; (ii) Your spouse's hours of employment are reduced; (iii) Your spouse's employment ends for any reason other than his or her gross misconduct; (iv) Your spouse becomes entitled to Medicare (Part A, Part B, or both); or (v) You become divorced or legally separated from your spouse. Your dependent children will become qualified beneficiaries if they will lose coverage because any of the following qualifying events happens: (i) The parent-employee dies; (ii) The parent-employee's hours of employment are reduced; (iii) The parent-employee's employment ends for any reason other than his or her gross misconduct; (iv) The parent-employee becomes entitled to Medicare (Part A, Part B, or both); (v) The parents become divorced or legally separated; or (vi) The child stops being eligible for coverage under the plan as a "dependent child." The Plan will offer COBRA continuation coverage to qualified beneficiaries only after the Plan Administrator (or a third-party COBRA administrator, as applicable) has been notified that a qualifying event has occurred. When the qualifying event is the end of employment or reduction of hours of employment, death of the employee, or entitlement of the employee to Medicare (Part A, Part B, or both), your Employer must notify the Plan Administrator (or a third- party COBRA administrator, as applicable) of the qualifying event within 30 days after the event or when you would otherwise lose coverage under the plan. For the other qualifying events (divorce or legal separation of the employee and spouse or a dependent child's losing eligibility for coverage as a dependent child), you must notify the Plan Administrator (or a third-party COBRA administrator, as applicable). The Plan requires you to notify the Plan Administrator (or a third-party COBRA administrator, as applicable) within 60 days after the qualifying event occurs or the date you would otherwise lose Page 10

coverage due to a qualifying event, whichever is later. You must send this notice to the Plan Administrator (or a third- party COBRA administrator, as applicable) in accordance with the procedures set forth below under "Furnishing Notice to Plan Administrator." Once the Plan Administrator receives notice that a qualifying event has occurred, COBRA continuation coverage will be offered to each of the qualified beneficiaries. For each qualified beneficiary who elects COBRA continuation coverage, COBRA continuation coverage will begin on the date that group health plan coverage would otherwise have been lost. COBRA continuation coverage is a temporary continuation of coverage. When the qualifying event is the death of the employee, entitlement of the employee to Medicare (Part A, Part B, or both), your divorce or legal separation, or a dependent child losing eligibility as a dependent child, COBRA continuation coverage lasts for up to 36 months. When the qualifying event is the end of employment or reduction of the employee's hours of employment, COBRA continuation coverage lasts for up to 18 months. However, with respect to the extension of coverage under the Health Care flexible spending account, if available, continuation coverage will extend only until the end of the plan year in which the qualifying event occurs. Generally, continuation coverage for a Health Care Flexible Spending Account will only be available if you have what is known as an "underspent" Health Care Flexible Spending Account, meaning if the amount you elected to contribute to your Health Care Flexible Spending Account exceeds the amount you have available to reimburse Qualifying Health Care Expenses at the time you terminate. There are two ways in which this 18-month period of COBRA continuation coverage can be extended. Disability extension of 18-month period of continuation coverage If you or anyone in your family covered under the group health plan is determined by the Social Security Administration (SSA) to be disabled at any time during the first 60 days of COBRA continuation coverage and you notify the Plan Administrator in a timely fashion, you and your entire family can receive up to an additional 11 months of COBRA continuation coverage, for a total maximum of 29 months. You must make sure that the Plan Administrator is notified of the SSA's determination within 60 days after the later of: (i) the date of the SSA determination; (ii) the date of a qualifying event; or (iii) the date you lose coverage under the plan. This notice should be sent to the Plan Administrator in accordance with the procedures set forth below under "Furnishing Notice to Plan Administrator." Second qualifying event extension of 18-month period of continuation coverage If your family experiences another qualifying event while receiving COBRA continuation coverage, and such event would result in loss of health coverage if the first qualifying event had not already occurred, the spouse and dependent children in your family can get additional months of COBRA continuation coverage, up to a maximum of 36 months. This extension is available to the spouse and dependent children if the former employee dies, becomes entitled to Medicare (Part A, Part B, or both), or gets divorced or legally separated. The extension is also available to a dependent child when that child stops being eligible under the group health plan as a dependent child. In all of these cases, you must make sure that the Plan Administrator is notified of the second qualifying event within 60 days after the later of (i) the date of the second qualifying event, or (ii) the date coverage under the plan would have been lost if the first qualifying event had not occurred. This notice must be sent to the Plan Administrator in accordance with the procedures set forth below under "Furnishing Notice to Plan Administrator." Furnishing Notice to Plan Administrator YOU SHOULD FOLLOW THESE PROCEDURES WHEN NOTIFYING THE PLAN ADMINISTRATOR (OR THIRD-PARTY COBRA ADMINISTRATOR, AS APPLICABLE) OF A QUALIFYING EVENT. FAILURE TO FOLLOW THESE PROCEDURES MAY CAUSE LOSS OF COVERAGE. Unless the Plan has a third-party COBRA administrator, in which case qualified beneficiaries should follow the notice procedures established by the third-party COBRA administrator, when furnishing a notice to the Plan Administrator with respect to the occurrence of a qualifying event or with respect to a disability determination by the Page 11

Social Security Administration, such notices will be delivered to the human resources department of the Plan Administrator (i) by hand-delivery, (ii) via facsimile, followed by written confirmation by first class mail, or (iii) by registered or certified mail, return receipt requested. Such notices will include the name(s) of the covered employee and/or qualified beneficiaries, as applicable, a general description of, and circumstances surrounding, the qualifying event or disability determination, and the date of such qualifying event or disability determination. Once the Plan Administrator receives such notice, it reserves the right to make further inquiry to verify the circumstances surrounding such qualifying event or disability determination. End of Continuation Coverage Continuation coverage will end earlier than the period elected if: Timely payment of premiums for the continuation coverage is not made; The qualified beneficiary first becomes covered under any other group health plan, after the COBRA election, as an employee or otherwise; The qualified beneficiary first becomes entitled to benefits under Medicare, after the COBRA election; The Plan Sponsor ceases to provide any group health plan to any employee; You, as the covered employee, cease to be disabled, if continuation coverage is due to your disability; or The period of continuation coverage expires. Health Insurance Marketplace You may have other options available to you when you lose group health coverage. For example, you may be eligible to buy an individual plan through the Health Insurance Marketplace. By enrolling in coverage through the Marketplace, you may qualify for lower costs on your monthly premiums and lower out-of-pocket costs. Additionally, you may qualify for a 30-day special enrollment period for another group health plan for which you are eligible (such as a spouse's plan), even if that plan generally doesn't accept late enrollees. For more information about the Marketplace, visit www.healthcare.gov. Medicare In general, if you don't enroll in Medicare Part A or B when you are first eligible because you are still employed, after the Medicare initial enrollment period, you have an 8-month special enrollment period to sign up for Medicare Part A or B, beginning on the earlier of: The month after your employment ends; or The month after group health plan coverage based on current employment ends. If you don't enroll in Medicare and elect COBRA continuation coverage instead, you may have to pay a Part B late enrollment penalty and you may have a gap in coverage if you decide you want Part B later. If you elect COBRA continuation coverage and later enroll in Medicare Part A or B before the COBRA continuation coverage ends, the Plan may terminate your continuation coverage. However, if Medicare Part A or B is effective on or before the date of the COBRA election, COBRA coverage may not be discontinued on account of Medicare entitlement, even if you enroll in the other part of Medicare after the date of the election of COBRA coverage. If you are enrolled in both COBRA continuation coverage and Medicare, Medicare will generally pay first (primary payer) and COBRA continuation coverage will pay second. Certain plans may pay as if secondary to Medicare, even if you are not enrolled in Medicare. For more information visit https://www.medicare.gov/medicare-and-you and https://www.medicare.gov/sign-up- change-plans/how-do-i-get-parts-a-b/part-a-part-b-sign-up-periods. Other Coverage Options You may also be eligible for Medicaid or Children's Health Insurance Program (CHIP), which, if eligible, may be a coverage option in lieu of COBRA and may cost less than COBRA continuation coverage. You can learn more about these options at: www.healthcare.gov or https://www.healthcare.gov/medicaid-chip/childrens-health-insurance- program/. Page 12

If you have questions If you have questions about your COBRA continuation coverage, you should contact the Plan Administrator or you may contact the nearest regional or district office of the U.S. Department of Labor's Employee Benefits Security Administration (EBSA). Addresses and phone numbers of regional and district EBSA offices are available through EBSA's website at www.dol.gov/ebsa. Keep your plan informed of address changes In order to protect your family's rights, you should keep the Plan Administrator (or third-party COBRA Administrator, as applicable) informed of any changes in the addresses of family members. You should also keep a copy, for your records, of any notices you send to the Plan Administrator. VI. DEPENDENT CARE ASSISTANCE ACCOUNT 6.1 What Is A Dependent Care Assistance Account? A Dependent Care Assistance Account (DCAP) allows eligible employees to set aside, on a pre-tax basis, monies to pay for qualifying dependent care expenses, which include expenses incurred for the care of an "eligible dependent," or for related household services, and are incurred to enable you and your spouse (if applicable, unless your spouse is a full-time student or disabled) to be gainfully employed. To be a qualifying dependent care expense, the money must be paid to any individual or organization other than your spouse, your child under age 19 at calendar year end, your dependent for income tax purposes, an overnight camp, or a childcare facility caring for more than 6 persons but not complying with all state or local requirements. 6.2 Who Is An Eligible Dependent? An "eligible dependent" must be one of the following: (i) a person who is your dependent child under the age of 13, who lives in your home for more than half the year, and who receives more than half of his or her support from you for the year; or (ii) a person who is your disabled dependent (other than as set forth in (i) above), who lives in your home for more than half the year, who receives more than half of his or her support from you for the year, and who regularly spends at least 8 hours a day in your home; or (iii) a person who is your disabled spouse, who lives in your home for more than half the year, and who regularly spends at least 8 hours a day in your home. 6.3 What Limits Apply? There is a $5,000 limit per family, except that if you are married and file separate tax returns, the limit is $2,500 per person. In addition, for each Plan Year, you are not entitled to any DCAP reimbursement in excess of your taxable compensation or your spouse's taxable compensation. The minimum amount you can elect to contribute your Dependent Care FSA is for the Plan Year is $120. Any expenses reimbursed from your DCAP cannot be used for Federal Child and Dependent Care tax credit, as described later. 6.4 How Does The Dependent Care Assistance Account Work? You elect to participate in the DCAP by providing a source of pre-tax funds to reimburse yourself for your qualifying dependent care expenses by entering into an election form/salary reduction agreement with your Employer. Under that agreement, you agree to a salary reduction to fund the DCAP instead of receiving a corresponding amount of your regular pay. As you incur qualifying dependent care expenses, you may obtain reimbursement by submitting a claim form to the Plan Administrator, or if applicable, a third-party administrator designated by the Plan Administrator from time to time. (See Section 11.2 of this Summary Plan Description.) Page 13

EMPLOYEES WHO FAIL TO USE (SPEND) 100% OF THE AMOUNT CREDITED TO THE DCAP FOR A CERTAIN PLAN YEAR WILL FORFEIT THE UNUSED PORTION AT THE END OF THE PLAN YEAR. 6.5 What Is The Dependent Care Tax Credit Currently, the amount of federal income taxes (but not FICA) you owe may be reduced by a percentage of the money you have spent on qualifying dependent care expenses. This is called a Dependent Care Tax Credit. The percentage varies depending on the combined income of you and your spouse. The total amount of expenses eligible for the credit is $3,000 for one qualifying dependent and to $6,000 for two or more dependents. These expenses are also eligible for payment through a DCAP. Note that you are not permitted to use both the Dependent Care Tax Credit and the DCAP, so you should evaluate both possibilities. A full explanation of the tax laws as they relate to dependent care expenses is beyond the scope of this Summary Plan Description. We encourage you to seek the assistance of a competent tax advisor if you are unsure about how to proceed. VII. PREMIUM DEDUCTIONS 7.1 How Are Employee Premiums For Health And Welfare Plans Paid? When you elect to participate in the health and welfare plans available under this Plan, your regular compensation will be reduced on a pre-tax basis by the amount of your premium payment (to the extent applicable) for the coverage selected under such plan(s). VIII. TERMINATION OF EMPLOYMENT 8.1 What Happens If My Employment is Terminated During the Plan Year? If your employment is terminated during the Plan Year, you will remain covered by the Plan Sponsor's health and welfare plans, but only to the extent permitted under each such plan and only for the period for which premiums have been paid prior to your termination. You will remain eligible for reimbursement for all qualified expenses incurred under your Health Care Flexible Spending Account and/or Dependent Care Assistance Account until the following: Health Care Flexible Spending Account: Up to the date your employment is terminated, provided that you make proper claims for reimbursement on or before 30 days immediately following your last day of employment. Dependent Care Flexible Spending Account: Up to the date your employment is terminated, provided that you make proper claims for reimbursement on or before 30 days immediately following your last day of employment. Under federal law, you, your spouse and your dependents may be entitled to continuation of health care coverage. (See Section 5.5 of this Summary Plan Description.) IX. HIGHLY COMPENSATED AND KEY EMPLOYEES 9.1 Do Limitations Apply To Those Who Are Highly Compensated? Under the Internal Revenue Code, "highly compensated individuals," "highly compensated employees" and "key employees" are Participants who are generally highly paid employees. If you are within these categories, the amount of your contributions and benefits may be limited so that the Plan as a whole does not unfairly favor those who are highly paid. Plan experience will dictate whether contribution limitations on "highly compensated individuals," "highly compensated employees" or "key employees" will apply. You will be notified of these limitations if you are affected. X. GENERAL INFORMATION ABOUT THE PLAN This section contains certain general information which you may need to know about the Plan. 10.1 General Plan Information The name of the Plan is the ACHIEVA Section 125 and FSA Plan. The Plan Sponsor has assigned Plan Number 501 to your Plan, and the Plan has been made part of the Plan Page 14

Sponsor's Health and Welfare Plan for Employees of ACHIEVA for annual reporting purposes. The Plan is effective July 1, 1992 amended and restated effective July 1, 2024. Your Plan's records are maintained on a fiscal period known as the Plan Year. Each Plan Year will run from July 1 through June 30. 10.2 Employer Information The Plan Sponsor's name, address, and identification number are: ACHIEVA 711 Bingham Street PITTSBURGH, Pennsylvania 15203 E.I.N.: 25-1505216 10.3 Plan Administrator Information The name, title, address, and business telephone number of your Plan Administrator is: ACHIEVA 711 Bingham Street PITTSBURGH, PA 15203 (412) 995-5000 The Plan Administrator keeps the records for the Plan and is responsible for the administration of the Plan. The Plan Administrator will also answer any questions you may have about the Plan. 10.4 Service Of Legal Process The name and address of the Plan's agent for service of legal process is: ACHIEVA 711 Bingham Street PITTSBURGH, PA 15203 10.5 Type Of Administration The Plan is administered by the Plan Administrator, who may delegate administrative duties to a third-party administrator from time to time. As applicable, the Plan Administrator will notify you who the third-party administrator is, and any applicable contact information, when you join the Plan. The Plan Administrator may change the third-party administrator from time to time, and you will be notified of any such change. The third-party administrator designated by the Plan Administrator is: UPMC Benefit Management Service PO Box 2784 Fargo, ND 58108 Telephone: (844) 220-4785 XI. ADDITIONAL PLAN INFORMATION 11.1 ERISA Rights And Protections Your Rights Under ERISA As a participant in the Plan, you are entitled to certain rights and protections under the Employee Retirement Income Security Act of 1974 (ERISA). ERISA provides that all Plan participants are entitled to: (i) Examine, without charge, at the Plan Administrator's office and at other specified locations, such as worksites and union halls, all documents governing the Plan, including insurance contracts and collective bargaining Page 15

agreements, and a copy of the latest annual report (Form 5500 Series) filed by the Plan with the U.S. Department of Labor and available at the Public Disclosure Room of the Employee Benefits Security Administration. (ii) Obtain copies of all Plan documents and other Plan information including insurance contracts and collective bargaining agreements, and copies of the latest annual report (Form 5500 Series) and updated summary plan description upon written request to the Plan Administrator. The Plan Administrator may make a reasonable charge for the copies. (iii) Receive a summary of the Plan's annual financial report. The Plan Administrator is required by law to furnish each participant with a copy of this summary annual report In addition, you may continue coverage under the Health Care Flexible Spending Account program for yourself, spouse or dependents if there is a loss of coverage under the Health Care Flexible Spending Account program as a result of a qualifying event. You or your dependents may have to pay for such coverage. You should review this Summary Plan Description and the documents governing the Health Care Flexible Spending Account program on the rules governing your COBRA continuation coverage rights. Prudent Actions by Plan Fiduciaries In addition to creating rights for Plan participants, ERISA imposes duties upon the people who are responsible for the operation of an employee benefit plan. The people who operate your Plan, called "fiduciaries" of the Plan, have a duty to do so prudently and in the best interest of you and other Plan participants. No one, including your employer or any other person, may fire you or otherwise discriminate against you in any way to prevent you from obtaining a benefit or exercising your rights under ERISA. Enforce Your Rights If your claim for a benefit is denied or ignored, you have a right to know why this was done, to obtain copies of documents relating to the decision without charge, and to appeal any denial, all within certain schedules. Under ERISA there are steps you can take to enforce the above rights. For instance, if you request a copy of plan documents or the latest annual report from the Plan and do not receive them within thirty (30) days, you may file suit in a Federal court. In such a case, the court may require the Plan Administrator to provide the materials and pay you up to $110 a day until you receive the materials, unless the materials were not sent because of reasons beyond the control of the Plan Administrator. If you have a claim for benefits which is denied or ignored, in whole or in part, you may file suit in a state or Federal court. In addition, if you disagree with the Plan's decision or lack thereof concerning the qualified status of a medical child support order, you may file suit in Federal court. If it should happen that Plan fiduciaries misuse the Plan's money, or if you are discriminated against for asserting your rights, you may seek assistance from the U.S. Department of Labor, or you may file suit in Federal court. The court will decide who should pay court costs and legal fees. If you are successful, the court may order the person you have sued to pay these costs and fees. If you lose, the court may order you to pay these costs and fees, for example, if it finds your claim is frivolous. Assistance with Your Questions If you have any questions about this Plan, you should contact the Plan Administrator. If you have any questions about this statement or about your rights under ERISA, including COBRA, HIPAA and other laws affecting the Plan or need assistance in obtaining documents from the Plan Administrator, you should contact the nearest area office of the Employee Benefits Security Administration, U.S. Department of Labor, listed in your telephone directory or the Division of Technical Assistance and Inquiries, Employee Benefits Security Administration, U.S. Department of Labor, 200 Constitution Avenue N.W., Washington, D.C. 20210. You may also obtain certain publications about your rights and responsibilities under ERISA by calling the publications hotline of the Employee Benefits Security Administration. You may also visit their website at www.dol.gov/ebsa. For all non-health care claims under the Plan, the following procedures set forth in Sections 11.2 through 11.5 will apply. For all health care claims under your health flexible spending account, Article XII of this Summary Plan Description will apply. Despite any other provision of the Plan, the claims procedures of Page 16

any third-party administrator of the Plan will supersede the procedures set forth below as long as such procedures comply with applicable law. 11.2 Filing A Claim (i) All claims for reimbursement from your Dependent Care spending accounts must be submitted during the Plan Year in which the expenses were incurred on or before 90 days immediately following the close of the Plan Year. (ii) With the claim form, you must submit a bill or receipt from the provider which gives the following information: (a) name and address of the provider and - in some cases - the provider's taxpayer identification number and signature; (b) the date(s) services were provided; (c) the type of service provided; and (d) who received the service. (iii) Instead of submitting a claim as set forth in (ii) above, the Plan Administrator has established a debit card program for the processing and reimbursement of all eligible benefits, and the details of such program will be explained to you if and when the program is established. 11.3 Notification Of Your Claim If any claim made under this Plan is wholly or partially denied, the Administrator will notify the person making such claim (the "claimant") of his or her decision in writing. You will receive a response to your claim within 90 days after your claim is submitted. More time may be required if there are special circumstances. If so, the Plan Administrator will contact you within the 90-day period. This notice will include an explanation as to why extra time is required and the date you can expect a decision. The extension will not exceed an additional 90 days. If the Plan Administrator fails to notify you within the designated time period, your claim will be considered to have been denied. Despite the foregoing, any claim made in connection with a Qualified Benefit Plan other than the Dependent Care Flexible Spending Account will be subject to review thereunder as required in Section 3.2 and will not be subject to review under this Article. 11.4 Claim Denial If all or part of your claim is denied, you will receive written notification explaining the reasons for the denial, reference to specific Plan provisions on which the denial is based, a description of any additional information or material needed to complete your claim and an explanation of why the information is necessary, and appropriate information about the Plan's claims review procedures, including a statement of your right to bring a lawsuit following a denial on review. 11.5 Appealing A Denied Claim If your claim is denied and you wish to appeal, you must file your appeal with the Plan Administrator within 60 days after you receive the denial. Your appeal should include any additional information that you wish the Plan Administrator to consider. If your appeal is not filed within this 60-day period, you will not be able to appeal your claim. The Plan Administrator will notify you in writing within 60 days after your appeal is received. If there are special circumstances, more time may be necessary to review your appeal. You may be asked to wait an additional 60 days for a decision. If all or part of your claim on appeal is denied, you will receive written notification explaining the reasons for the denial and reference to the specific Plan provisions on which the denial is based, a statement that you are entitled to receive, upon request and free of charge, reasonable access to, and copies of, all documents, records and other information relevant to your claim, and a statement of your right to bring a lawsuit following a denial on review. The decision will be final and binding on all parties. If you do not receive a written response from the Plan Administrator within the designated time period, your appeal will be considered to have been denied. Page 17

If you are dissatisfied with the decision after you have pursued these steps, you have the right to file a lawsuit in a state or federal court. XII. HEALTH CARE CLAIM PROCEDURES For all non-health care claims under the Plan, the following procedures set forth in Sections 11.2 through 11.5 will apply. For all health care claims relating to your Health Care Flexible Spending Account, this Article XII will apply. Despite any other provision of the Plan, the claims procedures of any third-party administrator of the Plan will supersede the procedures set forth below as long as such procedures comply with applicable law. 12.1 Health Care Claim Definition How you file a health care claim for benefits depends on the type of claim it is. There are several categories of benefits: (i) A "concurrent care claim" is a claim for an extension of the duration or number of treatments provided through a previously-approved benefit claim. (ii) A "pre-service care claim" is a claim for a benefit under the Plan with respect to which the terms of the Plan require approval (usually referred to as precertification) of the benefit in advance of obtaining medical care. (iii) A "post-service care claim" is a claim for a benefit under the Plan after medical care has been rendered. (iv) An "urgent care claim" is a claim for medical care or treatment that requires notification or approval prior to receiving medical care, where a delay in treatment could seriously jeopardize your life or health or the ability to regain maximum function or, in the opinion of a doctor with knowledge of your health condition, could cause severe pain. This type of claim generally includes those situations commonly treated as emergencies. 12.2 Filing A Health Care Claim If you wish to designate an authorized representative to act on your behalf with respect to your claim for benefits, you must do so in writing. Please be advised that no rights under the Plan, including but not limited to the right to receive any benefit or any right to pursue a claim or cause of action, are assignable. Any payment by the Plan directly to a provider pursuant to a written election or purported assignments submitted by a participant or a dependent is provided at the discretion of the Plan Administrator as a convenience to the participant or dependent and does not imply an enforceable assignment of any benefits or the right to pursue a claim or cause of action. The Plan Administrator has established a debit card program for the processing and reimbursement of all eligible health care expenses, and the details of such program will be explained to you if and when the program is established. However, in the absence of a debit card program established under this Plan or if a provider will not accept payment from a debit card under this Plan, all claims must be filed using a written form supplied by the Plan Administrator and may be submitted by U.S. Mail, by hand delivery or by facsimile. The Plan Administrator or its delegee provides forms for filing claims and authorized representative designations under the Plan that must be filed in writing. All claims from your Health Care Flexible Spending Account must be submitted during the Plan Year in which the expenses were incurred. Any claims not submitted on or before 90 days immediately following the close of the Plan Year will be rejected. Your claim for benefits should include the following: (i) the amount and nature of the qualifying health care expense (as described elsewhere in this Summary Plan Description under "Health Care Flexible Spending Account Program") for which you want to be reimbursed; (ii) the date that the care giving rise to the qualifying health care expense was provided; (iii) the name of the person receiving the care if such person is not you, and the relationship of such person to you; (iv) the name of the person to whom, or organization to which, the qualifying health care expense was incurred; (v) that the qualifying health care expense has not been reimbursed, or is not reimbursable, under any other health plan coverage; and (vi) a written statement or receipt from an independent third party that the qualifying health care expense has Page 18

been incurred and the amount of such qualifying health care expense. 12.3 Notification Of Your Health Care Claim Post-Service Claims If your Post-Service Claim is denied, you will receive a written notice from the Plan Administrator within 30 days of receipt of the claim, as long as all needed information was provided with the claim. The Plan Administrator will notify you within this 30- day period if additional information is needed to process the claim, and may request a one- time extension not longer than 15 days and hold your claim until all information is received. Once notified of the extension, you then have 45 days to provide this information. If all of the needed information is received within the 45-day time frame and the claim is denied, the Plan Administrator will notify you of the denial within 15 days after the information is received. If you don't provide the needed information within the 45- day period, your claim will be denied. Pre-Service Claims If your claim is a Pre-Service Claim, and it is submitted improperly, the Plan Administrator will notify you of the improper filing and how to correct it within 5 days. If your Pre-Service Claim is submitted properly with all needed information, you will receive written notice of the claim decision from the Plan Administrator within 15 days of receipt of the claim. The Plan Administrator will notify you within this 15-day period if additional information is needed to process the claim, and may request a one-time extension not longer than 15 days and hold your claim until all information is received. Once notified of the extension, you then have 45 days to provide this information. If all of the needed information is received within the 45-day time frame, the Plan Administrator will notify you of the determination within 15 days after the information is received. If you don't provide the needed information within the 45-day period, your claim will be denied. Urgent Claims If your claim is an Urgent Care Claim: You will receive notice of the benefit determination in writing or electronically within 72 hours after the Plan Administrator receives all necessary information, taking into account the seriousness of your condition. Notice of denial may be oral with a written or electronic confirmation to follow within 3 days. If you file an Urgent Care Claim improperly, the Plan Administrator will notify you of the improper filing and how to correct it within 24 hours after the Urgent Care Claim is received. If additional information is needed to process the claim, the Plan Administrator will notify you of the information needed within 24 hours after the claim was received. You then have 48 hours to provide the requested information. You will be notified of a determination no later than 48 hours after: The Plan Administrator's receipt of the requested information; or The end of the 48-hour period within which you were to provide the additional information. Concurrent Care Claim If an on-going course of treatment was previously approved for a specific period of time or number of treatments, and your request to extend the treatment is an Urgent Care Claim as defined above, your request will be decided within 24 hours, provided your request is made at least 24 hours prior to the end of the approved treatment. The claims administrator will make a determination on your request for the extended treatment within 24 hours from receipt of your request. If your request for extended treatment is not made at least 24 hours prior to the end of the approved treatment, the request will be treated as an Urgent Care Claim and decided according to the timeframes described above. If an ongoing course of treatment was previously approved for a specific period of time or number of treatments, and you request to extend treatment in a non-urgent circumstance, your request will be considered a new claim and decided according to post-service or pre-service timeframes, whichever applies. Page 19

12.4 Health Care Claim Denial The Plan Administrator will provide you with written notice of the denial of your claim. Such notice will include the following: (i) the specific reason(s) for your adverse benefit determination; (ii) reference to the specific Plan provision on which the determination is based; (iii) a description of any additional material or information necessary for you to fix your claim and an explanation of why such material or information is necessary; (iv) a description of the review procedures, including a statement of your right to bring a lawsuit following an adverse benefit determination on review; (v) either the specific rule or guideline used in making your benefits determination or a statement that such a rule or guideline was relied upon in making the determination and that a copy of such rule or guideline will be provided free of charge upon request; (vi) if the adverse benefit determination is based on a medical judgment, either an explanation of such judgment, or a statement that such explanation will be provided to you free of charge upon request; and (vii) in the case of an Urgent Care Claim, a description of the expedited review process to which you may be entitled. 12.5 Appealing A Denied Health Care Claim You have 180 days after the receipt of the denial notice to request a review of the denial. Your request for a review must be in writing unless your claim involves urgent care, in which case the request may be made orally. If you disagree with a claim determination, you can contact the Plan Administrator in writing to formally request an appeal. If the appeal relates to a claim for payment, your request should include: The patient's name and the identification number from the ID card, if any. The date(s) of health care service(s). The provider's name. The reason you believe the claim should be paid. Any documentation or other written information to support your request for claim payment. A qualified individual who was not involved in the decision being appealed will be appointed to decide the appeal. If your appeal is related to clinical matters, the review will be done in consultation with a health care professional with appropriate expertise in the field who was not involved in the prior determination. The Plan Administrator may consult with, or seek the participation of, medical experts as part of the appeal resolution process. You consent to this referral and the sharing of pertinent health claim information. Upon request and free of charge you have the right to reasonable access to and copies of, all documents, records, and other information relevant to your claim for benefits. Appeal Determination Notice Pre-Service and Post-Service Claim Appeals You will be provided with written or electronic notification of the decision on your appeal as follows: For appeals of Pre-Service Claims, the first level appeal will be conducted and you will be notified by the Plan Administrator of the decision within 15 days from receipt of a request for appeal of a denied claim. The second level appeal will be conducted and you will be notified by the Plan Administrator of the decision within 15 days from receipt of a request for review of the first level appeal decision. For appeals of Post-Service Claims, the first level appeal will be conducted and you will be notified by the Plan Administrator of the decision within 30 days from receipt of a request for appeal of a denied claim. The second level appeal will be conducted and you will be notified by the Plan Administrator of the decision within 30 days from receipt of a request for review of the first level appeal decision. Page 20

For procedures associated with Urgent Claims, see "Urgent Claim Appeals" below. If you are not satisfied with the first level appeal decision of the Plan Administrator, you have the right to request a second level appeal from the Plan Administrator. Your second level appeal request must be submitted to the Plan Administrator within 60 days from receipt of first level appeal decision. Please note that the Plan Administrator's decision is based only on whether or not benefits are available under the group health plan for the proposed treatment or procedure. The determination as to whether the pending health service is necessary or appropriate is between you and your doctor. Urgent Claim Appeals Your appeal may require immediate action if a delay in treatment could significantly increase the risk to your health or the ability to regain maximum function or cause severe pain. In these urgent situations, the appeal does not need to be submitted in writing. You or your doctor should call the Plan Administrator as soon as possible, and provide the Plan Administrator with the information identified above under "How to Appeal a Claim Decision." The Plan Administrator will provide you with a written or electronic determination within 72 hours following receipt of your request for review of the determination taking into account the seriousness of your condition. (i) Urgent Care Claims - not later than 72 hours after receiving your request for a review. (ii) Pre-Service Claims - not later than 30 days after receiving your request for a review. (iii) Post-Service Claims - not later than 60 days after receiving your request for a review. Similar to the initial claim determination period, these review periods may be extended. If these periods are extended, you will be notified by the Plan Administrator. Appeal Determination Notice If denied, your review decision on appeal will include: the specific reason(s) for the adverse determination; reference to the specific Plan provision on which the benefit determination is based; a statement that you are entitled to receive, without charge, reasonable access to any document (i) relied on in making the determination, (ii) submitted, considered, or generated in the course of making the benefit determination, (iii) that demonstrates compliance with the administrative processes and safeguards required in making the determination, or (iv) that constitutes a statement of policy or guidance with respect to the Plan concerning the denied treatment without regard to whether the statement was relied on; either the specific rule or guideline used in making your benefits determination or a statement that such a rule or guideline was relied upon in making the determination and that a copy of such rule or guideline will be provided free of charge upon request; if the adverse determination is based on medical necessity or experimental treatment or a similar exclusion or limit, either an explanation of the scientific or clinical judgment applying the terms of the Plan to your medical condition, or a statement that such explanation will be provided without charge on request; a statement describing the Plan's optional appeals procedures, and your right to receive information about such procedures, as well as your right to bring a lawsuit; and the following statement: "You and your Plan may have other voluntary alternative dispute resolution options, such as mediation. One way to find out what may be available is to contact your local U.S. Department of Labor Office and your State insurance regulatory agency." If you file an internal appeal for medical benefits, you will continue to be covered pending the outcome of the internal appeal. This means that the Plan shall not terminate or reduce any ongoing course of treatment without providing advance notice and the opportunity for review. Page 21

APPENDIX A Qualifying Health Care Expenses Under the Plan, you will be reimbursed only for those types of medical expenses normally deductible on your federal income tax return (without regard to the 7.5% of adjusted gross income limitation). They include, for example, expenses you have incurred for: (i) Medicine, drugs, birth control pills, vaccines, and vitamins you are prescribed by your physician. (ii) Over the counter drugs deemed qualifying by the Internal Revenue Service under Code §213 (e.g., antacids, cold medicine, pain relievers and allergy medicine). (iii) Personal protective equipment ("PPE"), such as masks, hand sanitizer and sanitizing wipes, for the primary purpose of preventing the spread of the Coronavirus Disease 2019 (COVID-19 PPE). (iv) Menstrual care products. (v) Medical doctors, dentists, eye doctors, chiropractors, osteopaths, podiatrists, psychiatrists, psychologists, physical therapists, acupuncturists and psychoanalysts (medical care only). (vi) Medical examination, X-ray and laboratory service, insulin treatment, and whirlpool baths the doctor ordered. (vii) Nursing help. If you pay someone to do both nursing and housework, you can be reimbursed only for the cost of the nursing help. (viii) Hospital care (including meals and lodging), clinic costs, lab fees. (ix) Medical treatment at a center for drug addicts or alcoholics. (x) Medical aids such as hearing aids (and batteries), false teeth, eyeglasses, contact lenses, braces, orthopedic shoes, crutches, wheelchairs, guide dogs and the cost of maintaining them. (xi) Ambulance service and other travel costs to get medical care. If you use your own car, you can claim what you spend for gas and oil to go to and from the place you received the care; or you can claim the per-mile reimbursement rate established by the Internal Revenue Service as in effect at the time the travel costs are incurred. Add parking and tolls to the amount you claim under either method. You cannot obtain reimbursement for: (i) Expenses for which reimbursements are already available under another group health plan. (ii) Premiums paid for health coverage under any plan maintained by your Employer or any other employer. (iii) The basic cost of Medicare insurance (Medicare A). (iv) Life insurance or income protection policies. (v) The hospital insurance benefits tax withheld from your pay as part of the social security tax or paid as part of social security self-employment tax. (vi) Maternity clothes. (vii) Diaper service. (viii) Nursing care for a healthy baby. (ix) Illegal operations or drugs. (x) Travel your doctor told you to take for rest or change. (xi) Funeral expenses. Qualifying medical expenses include only those expenses incurred for: (i) Yourself. Page 22

(ii) Your spouse. (iii) All dependents you list on your federal income tax return. (iv) If you are divorced or separated, any child of yours that is listed as a dependent on his or her other parent's federal income tax return (and certain other individuals in the case of a multiple support agreement). IRS Publication 502, Medical and Dental Expenses, has a checklist of medical expenses that can be deducted and therefore reimbursed under this Plan, and those that cannot. Page 23

ACHIEVA SECTION 125 AND FSA PLAN Schedule A - Participating Employers As of July 1, 2024, unless otherwise noted Each entity listed below has sufficient common ownership with the Employer so as to constitute a member of a commonly controlled group as described in Code §414(b), (c), (m), and (o) and has adopted the Plan with the consent of the Plan Sponsor. None Page 24