Second phase of Orange County’s forensic audit reviewed 681 contracts worth $1.7 billion and found the warning signs around a supervisor’s daughter were raised early — and repeatedly ignored

Orange County officials were told in March 2023 that the daughter of then-Supervisor Andrew Do was running a nonprofit receiving county subcontract money. The concern was raised by the nonprofit’s own prime contractor, escalated through the Health Care Agency, and carried all the way to the county’s chief executive.

It was not formally investigated until November of that year, after a public records request and an LAist story on Rhiannon Do’s role made the arrangement public. (LAist published its report on November 22, 2023.)

That timeline is the centerpiece of the second phase of an independent forensic audit of county contracting, presented to the Orange County Board of Supervisors on August 25 by Weaver and Tidwell, L.L.P. The Phase 2 report covers 681 contracts worth roughly $1.7 billion awarded between January 2019 and August 2024, and it is the second of four planned installments in a review of more than 2,500 contracts totaling about $4.3 billion.

The board ordered the audit in December 2024, two months after Do resigned his District 1 seat as part of a federal plea deal. Do pleaded guilty to conspiracy to commit bribery, admitting he accepted more than $550,000 in bribes while steering over $10 million in pandemic relief funds to the Viet America Society, where his daughter Rhiannon Do was employed. He was sentenced in June 2025 to five years in federal prison.

The new report does not accuse anyone of a crime. What it describes instead is a set of internal controls that repeatedly failed to catch — or chose not to escalate — problems that were visible to the people closest to the contracts.

Rhiannon Do was never charged. Here’s the arc, all from public court records and reporting.

Prosecutors accused her of making a false statement on a loan application — a mortgage of more than $600,000 obtained with false information and fabricated documents — and in a diversion agreement filed as an exhibit to her father’s plea deal. According to the U.S. Attorney’s Office, she admitted her conduct was criminal and violated federal and state law. The charge was deferred rather than filed, allowing her to enter diversion in exchange for cooperation. She also agreed to forfeit the Tustin home. 

Prosecutors said she was paid $8,000 a month from September 2021 through February 2024 — $224,000 total — and that in July 2023, $381,500 from Viet America Society went into escrow so she could buy a $1.035 million house in Tustin. 

Since then, she graduated from law school last year and passed the California bar exam, but is not currently listed as an attorney on the state bar’s website. Orange County’s civil suit against Andrew Do, Rhiannon Do and others is set for trial in late 2027, and federal prosecutors have an ongoing criminal case against two alleged co-conspirators, Peter Pham and Thanh Huong Nguyen.

Audit Reveals Controversies Surrounding Warner Wellness Center’s Subcontracting with OCAPICA

The audit’s most detailed section concerns Warner Wellness Center, a subcontractor on a mental health outreach program run by the Orange County Asian and Pacific Islander Community Alliance, or OCAPICA.

OCAPICA had proposed 12 subcontractors of its own, each vetted in advance. According to meeting minutes cited by the auditors, the Health Care Agency told OCAPICA during August 2022 contract negotiations that the board wanted room for organizations that had never worked with the county before — and that $600,000 had been set aside for a specific group of them. Warner Wellness was on that list. It was the only one OCAPICA had never partnered with.

The direction came from then-HCA Director Dr. Clayton Chau, who told auditors he was chiefly responsible for picking the subcontractors. Weaver found contemporaneous records pointing elsewhere: to the board’s Behavioral Health Ad Hoc Committee, whose members included Supervisor Andrew Do and former Supervisor Lisa Bartlett. Auditors could not locate any minutes for that committee.

Problems surfaced immediately. In August 2022, OCAPICA told HCA it could not find Warner Wellness registered with the state or the IRS as a nonprofit. In December, it discovered the business license was in a different name and had to void a signed subcontract and reissue it. “Warner Wellness is really Viet America Society,” an OCAPICA staffer wrote to the county’s program manager. “All of their paperwork is through this nonprofit.“

By late February 2023, OCAPICA had learned that Rhiannon Do — who had signed the subcontract as executive director — was Supervisor Do’s daughter, and flagged it to HCA. Dr. Veronica Kelley, then HCA’s chief of mental health and recovery services, confirmed the role on Rhiannon Do’s LinkedIn page and brought it to Chau along with the agency’soperations director. Chau said the information was wrong. Shown the LinkedIn page, he said he would speak with Supervisor Do, then reported back that it was inaccurate.

In a separate meeting around the same time, a program manager who raised the issue told auditors Chau verbally reprimanded him, saying Supervisor Do “was an attorney and he would know if there was a conflict.“

Kelley took it above Chau to then-County Executive Officer Frank Kim. Kim did not go to County Counsel. He called Do’s chief of staff, Chris Wangsaporn, who told him there was “no affiliation or conflict.” Kim relayed that back, and HCA proceeded.

Rhiannon Do was in fact employed by Warner Wellness at the time. Kim later told auditors that after a November 2023 news article (LAist, November 22, 2023: “Top OC official helped direct millions to daughter’s center without disclosing family connection,” by Nick Gerda.), he confronted Wangsaporn and “felt lied to.” Wangsaporn, according to Kim, said he had only ever claimed there was no conflict — not that she didn’t work there. Wangsaporn did not respond to Weaver’sinterview request.

OCAPICA issued four corrective action notices to Warner Wellness before terminating the subcontract effective April 8, 2024. Warner Wellness had been paid $257,915.

Weaver’s recommendation: require that conflict-of-interest allegations be formally documented and resolved by County Counsel or an independent ethics function. The report notes the allegation was never reported through the county’s fraud hotline.

The audit also examined a $500,000 CARES Act grant awarded in May 2021 to Bridgecreek Realty Investment Corp. for outdoor dining structures in Westminster’s Little Saigon Business District — one of several District 1 small business relief grants.

Bridgecreek’s final report accounted for the full $500,000 on a spreadsheet, but supplied invoices, receipts or bank statements for only $231,404 of it. The remaining $268,596 — 54% — went undocumented. All of the documentation provided covered December 2021; nothing was supplied for May through November. The county’s contract, auditors noted, never explicitly required receipts.

When the contract expired in November 2021 with roughly $225,000 unspent, Bridgecreek asked for an extension, citing wind damage. Standard practice would have been to return the money and issue a new contract. Internal emails show OC Community Resources instead amended the expired agreement, at District 1’s preference, to avoid delay. Bridgecreek spent the balance between December 14 and December 30.

Among those December expenditures: $35,222 paid to HD Construction on December 14 for a folding gate, a double gas grill, tables, chairs and artwork — all for Perfume River Restaurant, and all retained by the restaurant rather than kept as shared outdoor dining infrastructure. HD Construction is affiliated with Peter Pham, who Phase 1 auditors determined had remodeled Do’s kitchen in March 2021, was connected to Perfume River’s parent company, and was president of Viet America Society.

Bridgecreek CEO Frank Jao told auditors Do approached him about the grant opportunity, and that Perfume River asked to have the purchases reimbursed. Weaver confirmed via satellite imagery that the dining structures were built at four locations.

A third section covers RX Consultants Group, doing business as Mercy Pharmacy, which billed the county $748,720 for COVID-19 vaccinations between January and June 2021.

Mercy’s president emailed HCA unsolicited on December 29, 2020. The pharmacy was administering vaccines for the county by January 2. A contract was not executed until April 29 — nearly four months later — and was backdated to January 6. Auditors found no documentation of a vendor selection process: no comparison of providers, no evaluation of qualifications, no sole source justification form. HCA staff told Weaver that Chau was friends with Mercy Pharmacy and wanted to use them because they did good work.

The contract required monthly claim data. None was provided. The invoices listed only monthly dose counts and event counts, with no breakdown of insured versus uninsured patients and no documentation of denied claims. They were approved and paid anyway. HCA began requiring reconciliation reports in July 2021.

Beyond the individual contracts, Weaver flagged two systemic findings:

• Eight contracts worth $10.7 million were executed more than 30 days after work had already started — four at HCA, four at OC Community Resources. Only one had the required retroactive approval form.
• Twenty-eight contracts worth $237.2 million were awarded through an RFP process that drew exactly one proposal. Twenty-five were HCA contracts, many for behavioral health services. Weaver stopped short of calling this a deficiency, but recommended the county write guidance for single-bidder awards, which it currently lacks.

The report also revisits 360 Clinic, the COVID-19 testing vendor examined in Phase 1. At the board’s request, Weaver reviewed the 68,935 uncollectible test claims the county paid at $50 apiece. 360 Clinic told auditors it no longer has staff to compile the supporting records, so Weaver cross-checked patient names and service dates against lab data from Fulgent Labs. It verified 96% of the tests. It could not verify 2,646 of them — $132,300 in payments, including 1,574 that appeared to be double-billed. Weaver recommended referring the matter to County Counsel to determine whether the money can be recovered.

In its formal responses, the County Executive Office pointed to existing safeguards: Form 700 filings, conflict attestations for evaluation panel members, biannual ethics training for procurement agents, and Contract Policy Manual provisions governing retroactive transactions. It noted a procedure adopted two years ago requiring anyone responsible for a retroactive transaction to retake ethics training, with repeat offenders referred to department heads.

Board Chairman Doug Chaffee stated that the county has “made some changes since then” and will address the remaining recommendations. Vice Chair Katrina Foley noted that the report revealed “deficiencies in oversight and accountability that the board continues to address,” emphasizing that the remaining two phases are necessary to identify what still needs to be resolved.

The Weaver Forensic Auditing firm had no power to compel testimony or documents from anyone. In April 2026, the Internal Audit Department hired a separate firm to audit the county’s ethics program, including the fraud hotline.

Phases 3 and 4 will cover another 1,726 contracts worth roughly $2.1 billion.

The full Phase 2 report is available through the Orange County Internal Audit Department at iad.oc.gov or https://iad.oc.gov/audit-reports/fiscal-year-2025-26.