We draw our summary of the facts from the administrative record, deferring to the department's findings and reserving certain facts for later discussion. See McGovern v. State Ethics Comm'n, 96 Mass. App. Ct. 221, 222 (2019) ; Zoning Bd. of Appeals of Canton v. Housing Appeals Comm., 76 Mass. App. Ct. 467, 473 (2010). Pokwa's participation in the department's EA program began in July 2015.