Orange County Supervisor Andrew Do, one of the county’s most powerful elected officials, has voted to fund millions of dollars to an organization led by his daughter without publicly disclosing his close family connection, an LAist investigation has found.

Do voted twice to award contracts that, according to county agenda records, included subcontracts to Warner Wellness Center, his daughter Rhiannon Do’s group. Warner Wellness is the DBA of the nonprofit Viet America Society. (A DBA is the name an organization uses to operate that’s different from its legal name.)

During public discussion of one of those votes, Do said he had two years of conversations with the top county health official leading up to the vote.

Both of Do’s votes to fund the subcontracts happened with no public mention that his daughter was working as Warner Wellness’ president.

Do, his daughter, and Do’s chief of staff Van Tran haven’t returned multiple phone and email requests for comment.

A group of community nonprofit leaders were so concerned about the handling of the subcontracts that they held a meeting about it with Connie Chung Joe, the leader of L.A.’s top Asian American civil rights group.

Joe, who is CEO of Asian Americans Advancing Justice Southern California, told LAist she followed up by contacting the FBI.

When asked about this, FBI spokesperson Laura Eimiller told LAist her agency doesn’t confirm or deny the existence of investigations.

Conflicts of interest have previously emerged during Do’s time as a supervisor. Last year, Do paid the largest conflict of interest fine in California since 2019, according to state records.

Part of the fine was for Do not disclosing his role in fundraising that ultimately paid for work done by the founder of Viet America Society.

A nonprofit 'not in good standing'

Over a two-and-a-half-year span, Do was involved in directing $3.1 million to Warner Wellness, as well as an earlier $4.2 million to Viet America Society before it took on the Warner Wellness name as a DBA.

Viet America Society was incorporated in 2020 by Peter Pham, who previously worked on a high-profile statue project led by Do.

In budget records, Do took credit for Viet America Society’s county funding. And in a recent video touting Pham’s work, Do said he came up with the idea of expanding Viet America Society’s meal distribution.

“I approached Peter and said ‘Look, why don’t we blow this up, make it bigger and we can help more seniors,’ and that’s how we started working with him,” Do said in the video.

By the end of 2020, Viet America Society started receiving its first of several county contracts. By April 2022, it had received $4.2 million in contracts to prep and deliver hot meals to seniors, people with disabilities and others facing food insecurity in Do’s district.

Throughout those years, Viet America Society was not a legally registered nonprofit with the state — despite state law requiring registration within 30 days of receiving funds. Even after it registered in January 2023, the state warned the group in April that it was out of compliance. The AG’s office wrote that Viet America Society was “not in good standing and is prohibited from engaging in conduct for which registration is required, including soliciting or disbursing charitable funds.”

All along, county records show Viet America Society received funding approvals from the county anyway. It ultimately filed the required financial disclosures in June 2023.

County spokespeople have not answered whether the supervisors and county staff knew the county was approving millions in funding to a group the state had declared was unable to legally seek or spend funds .

“If they’re not registered and they’re operating, that’s illegal,” said Sean McMorris, the transparency, ethics and accountability program manager at California Common Cause.

Pham, the founder and president of Viet America Society, initially told LAist he would be available for an interview, but has not returned multiple follow-up calls to schedule it.

A family connection

O.C. Supervisors Vicente Sarmiento and Katrina Foley, who participated in a key vote on the center’s funding this May, told LAist they were not aware of Do’s family connection until LAist contacted them this month. Sarmiento said such family connections should be disclosed before votes.

The May vote approved an expansion of the county’s hotline contract with the local chapter of the National Alliance on Mental Illness (NAMI OC) to add services in Spanish and Vietnamese.

That expansion included a $2.5 million subcontract for Warner Wellness — outlined in county agenda documents for the vote — to provide Vietnamese language services for the WarmLine, the county’s emotional support hotline for people struggling with mental health challenges.

When that item came up for a vote, Do discussed being involved in conversations to expand the WarmLine’s services.

“I want to thank Dr. Chau,” Do said. He was speaking of Clayton Chau, attending the meeting in his role as the county’s top public health official. Chau’s department recommended the item for supervisors’ approval.

“To see this coming, now, after you and I have talked about it for over two years,” Do said to Chau. Do then voted with the other supervisors to approve the item, without disclosing his family relationship to the subcontractor.

It was not the first time Warner Wellness received funding through a county subcontract Do voted to fund.

County supervisors previously approved funding for a $625,000 subcontract with Warner Wellness in November 2022. Do, who voted for it, made no mention of his family connection. The funding was part of a contract with Orange County Asian and Pacific Islander Community Alliance (OCAPICA), one of Orange County's best-known Asian American community organizations, to provide mental health outreach in local communities.

Offices marked for Warner Wellness and Viet America Society are located on the same floor of the same office building as Do’s private law office in Huntington Beach. Until LAist contacted her this month, his youngest daughter Rhiannon Do listed herself on LinkedIn as president of Warner Wellness since July 2021.

After LAist contacted Rhiannon Do for comment, her title was updated to vice president. A week later, the person who answered the phone at Warner Wellness told LAist that Rhiannon Do was still the organization’s leader. The center’s website says it’s “a nonprofit, outpatient mental health center” but does not name anyone involved in the organization, including its leadership.

Do’s daughter is a law student at U.C. Irvine. She graduated from high school four years ago and then earned a bachelor’s degree in economics from U.C. Davis in December 2021. While at U.C. Davis, she interned at the Steinberg Institute, which advocates for statewide mental health policy changes. Her LinkedIn resume lists another internship at a law firm and no other work experience.

Rhiannon Do in a YouTube video posted in August 2021 by the Steinberg Institute where she was an intern.

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How Warner Wellness became a subcontractor

NAMI OC President Steve Pitman oversees Warner Wellness’ $2.5 million WarmLine subcontract. In written responses to LAist’s questions, he described Warner Wellness as a natural partner choice that was suggested to them as “county-vetted.”

OCAPICA’s executive director, Mary Anne Foo, told LAist that Warner Wellness was not part of her organization’s proposal to the county. Instead, the center was later suggested to her group during negotiations with the county after OCAPICA won the main contract. OCAPICA added Warner Wellness as a subcontractor before supervisors voted to approve the contract.

Chau, who no longer works at the county, didn’t return phone calls and text messages for comment to his cell phone or messages left with his new boss. Orange County CEO Frank Kim also didn’t return phone calls and text messages.

OC’s ethics code

County staff have not answered whether the handling of the Warner Wellness subcontracts complied with Orange County’s ethics policies, which state:

The code of ethics also says that county officials cannot participate in any activities that “would tend to impair independence of judgment or action in the performance of official duties.”

The code itself doesn’t describe consequences for any violations of these provisions, and county staff haven’t answered questions about whether any consequences exist.

Orange County has a five-member ethics commission, appointed by the five county supervisors. It has jurisdiction over some ethics code provisions, but not the ones listed above.

Tracy Westen, a government ethics expert, said the votes by Do raise ethical questions about why he didn’t publicly disclose his close family connection and recuse himself. Those factors, he said, lead to questions that should now be answered: How was the group was chosen? How is it performing? Was it given preferential treatment?

“I think it’s always a mistake for a public official to vote on something that can affect him, her or their family,” said Westen, who previously ran the L.A.-based Center for Governmental Studies.

“It’s one thing to vote on things that affect his family if it’s disclosed openly, candidly,” Westen said. “But it’s another to vote on something that affects your family positively, without disclosing it.”

Spokespeople for the county Health Care Agency have yet to answer questions submitted nearly two weeks ago about whether Do had a role in the selections of his daughter’s group as a subcontractor, whether county ethics policies were followed, and how Warner Wellness has been performing.

Instead, a spokesperson for the agency responded that responsibility for overseeing Warner Wellness’ work under the subcontracts lies with the contractors, NAMI OC and the Orange County Asian and Pacific Islander Community Alliance (OCAPICA).

Is it legal to steer government contracts to your child?

State law currently limits elected officials from approving contracts that benefit the official’s spouse — or child if they’re under 18 and can be claimed as a dependent.

But those conflict of interest rules do not apply when officials’ children are over 18.

Back in 2016, the Legislature had a lot of momentum to change that.

Then-Senator Tony Mendoza introduced a bill that year to expand the conflict definition to officials’ adult children, parents and siblings. Violations would result in “disqualification from ever holding any office in California in addition to prison time and/or a fine” of up to $1,000, he said in a news release at a time.

That ban would have applied only when officials were aware of a conflict.

It had major momentum — winning unanimous approval in the State Senate followed by unanimous yes votes by two Assembly committees. But it died before reaching a full Assembly vote, state records show.

The bill was inspired in part by a City of Industry audit that found more than $300 million in contracts with its former mayor’s family.

There’s a strong argument that conflict of interest laws should include officials’ adult children — as well as siblings and parents — said McMorris, the ethics advocate at Common Cause.

“I mean, you’re still blood relatives,” he said.

“The natural inclination of mothers and fathers is to want to assist their sons and daughters. So I’m not sure that exempting sons and daughters once they turn 18 years old necessarily passes the smell test when it comes to things like this.”

The NAMI OC subcontract

The NAMI OC subcontract with Do’s daughter’s group for $2.5 million — to provide Vietnamese language services for the WarmLine — was the larger of the two county-funded subcontracts with Warner Wellness.

NAMI OC is one of the best-known mental health organizations in Orange County.

Pitman, the NAMI chapter’s president, initially agreed to an interview through the group’s executive director but later provided written answers to questions from LAist instead.

Pitman wrote that it was the county that suggested expanding the WarmLine, and that county officials suggested Warner Wellness as a subcontractor for Vietnamese-language services.

Warner Wellness Center’s office in Huntington Beach on Nov. 8, 2023. It’s a few doors down from O.C. Supervisor Andrew Do’s private law office in the same building.

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“We were provided a short list of community-driven, county-vetted organizations to provide NAMI OC WarmLine sub-contract services,” Pitman wrote.

“Warner Wellness is a natural partner choice because we have bilingual volunteers who previously helped with Vietnamese community outreach efforts for the WarmLine now connected to Warner Wellness. Those volunteers are well versed in NAMI OC WarmLine functions.”

He did not directly answer whether Do’s daughter has been paid under the county-funded subcontract or specifically how her group has been performing over the six months since the county funding was approved.

“NAMI OC works closely with Warner Wellness and [Spanish-services provider] Abrazar to ensure quality interactions to best serve the community,” Pitman wrote.

“We review and process payments for services laid out in the sub-contract agreement. Subcontractors must provide appropriate documentation to support invoices .”

The OCAPICA subcontract

On Nov. 29 of last year, Do was among the five supervisors who voted for a contract with Orange County Asian and Pacific Islander Community Alliance (OCAPICA), which included a $625,000 subcontract to Warner Wellness Center for mental health outreach. Warner Wellness was named in the county agenda documents as receiving the subcontract funding, though Do did not publicly disclose his immediate family relationship to the group.

OCAPICA, a well-respected group run by Foo, oversees 16 subcontractors to perform outreach to Asian communities under the county contract.

Do’s daughter’s group was one of two groups to receive the largest subcontracts given, for $625,000. Most of the other 16 subcontractors received $100,000 or less, according to the county’s summary of the OCAPICA contract, which was attached to the agenda for the supervisors’ vote.

Foo declined to say who recommended Do’s daughter’s group during county negotiations, saying she doesn’t want to get that person in trouble.

“In any subcontracting case, we do really strong monitoring to make sure they’re successful,” she said, speaking generally.

“And if there’s any issues, we would definitely do corrective actions and make sure that everyone’s doing what they’re supposed to be doing.”

A pay-to-play fine

Last year, Do paid a $12,000 fine for violating the state’s “pay-to-play” laws on government contracts and for failing to disclose his role in nonprofit fundraising by required deadlines. That fine is the largest conflict of interest fine statewide since 2019, according to online records of the Fair Political Practices Commission, which enforces these laws.

The fine was based on two distinct issues.

One had to do with Do’s fundraising for the high-profile statue project at Mile Square Park in Fountain Valley. The project placed statues of President Ronald Reagan, Vietnamese General Trần Hưng Đạo and Spanish priest Miguel Hidalgo in 2015 and 2016.

Pham led construction work at the park for two of the statutes in 2015 and 2016, before founding Viet America Society in 2020 and creating Warner Wellness Center in 2021. His partner on the statue work was Le Dan Hua, who also later was a board officer at Viet America Society and Warner Wellness.

Do filed a required disclosure about his role requesting $40,000 in donations for the statues over two years late, after investigators contacted him, according to a report by state investigators.

During their probe, state investigators also determined that Do falsely told them — under penalty of perjury — that he never directly asked for donations into the nonprofit he was using to fund the statues.

“Do submitted false information to [FPPC] Enforcement under penalty of perjury — casting serious doubt on his credibility, such that any denials by him may be disbelieved, entirely,” the state enforcement agency wrote in a report last year.

State investigators found that the nonprofit that collected donations and paid for the statues — including Pham’s work — was being used as “a money holding company” controlled by Do and one of his top county aides.

Peter Pham was paid $20,800 for construction work at Do’s behest, according to a state investigation report. Pham was not accused of any wrongdoing.

The second type of violation cited in the fine was issued for votes he made as a county-appointed board member of the public health insurance plan CalOptima, to award lobbying contracts to two of his campaign donors.

“Do made, participated in making, and attempted to use his official position to influence governmental contracting decisions involving a participant who contributed to his campaign,” read the findings from the state Fair Political Practices Commission.

At the time, Do blamed agency staff for not notifying him about the potential conflicts of interest. But state investigators noted Do has extensive experience in law and government office.

Do is married to Cheri Pham, one of Orange County's highest ranking judges. Before being elected to the O.C. Board of Supervisors in a special election in 2015, Do served on the Garden Grove city council and worked as a prosecutor with the O.C. District Attorney’s office.

“In light of this background, it is fair to say that Do is a sophisticated public official who had ample reason to know and understand the requirements of the Act,” FPPC investigators wrote in their description of the fine.

As part of his $12,000 settlement, Do agreed that he violated the pay-to-play law and failed to file donation disclosures on time about his role in the statue fundraising.

He did not admit to making false statements, which were not part of the ultimate fine.

Mailings by Do prompted a change to state law

A few years before the $12,000 ethics fine, state law was changed in response to Do’s use of taxpayer money to send mailers from his supervisorial office during the 2016 re-election campaign.

Do sent out 1.2 million mailers to voters in his supervisorial district — many of which prominently showed his name and photo — shortly before Election Day. Do’s taxpayer-funded mass mailings helped prompt the state Legislature to ban county supervisors from sending out county-funded mailers featuring themselves within 60 days of elections where they’re on the ballot.

“There’s been some abuse by some elected officials who use public funds to mail what seems to be and look like political mailers,” Mendoza, the then-state senator who sponsored the bill, said when the new law was passed in 2017, citing Do in particular.

Response from O.C. supervisors

LAist called all five current county supervisors for this story, and spoke with the three who responded. Two said they weren’t aware of Do’s family connection to the subcontractor.

“This is the first I’m hearing about this,” said Supervisor Foley, who voted to fund both of the Warner Wellness subcontracts. She said she would be following up with her staff to look into it.

“That is news to me,” said Supervisor Sarmiento, who voted in favor of the WarmLine expansion that included the Warner Wellness subcontract after he joined the board this year. He said supervisors should disclose their family relationships with vendors, even if it’s not legally required.

O.C. Supervisor Don Wagner said he sees nothing wrong with what Do did, because there’s no legal requirement for officials to disclose or recuse themselves when their votes would financially benefit their adult children.

“I don’t find any fault with Supervisor Do’s conduct,” he told LAist. Wagner did not respond to questions from LAist about whether he knew about Do’s daughter’s involvement prior to his vote for the contracts.

Supervisor Doug Chaffee, who also voted for the contracts, didn’t return LAist’s requests for comment.

Do’s outside income

The outside of O.C. Supervisor Andrew Do’s law office in Huntington Beach, a few suites away from Warner Wellness Center and Viet America Society’s offices.

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Nick Gerda / LAist

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Among the county supervisors, Do is an outlier in how much money he’s received from undisclosed sources for outside work, according to an LAist review of public disclosures for recent years.

As a supervisor, Do made $231,000 last year in pay and benefits, according to public records posted by Transparent California. As one of five supervisors in a county of 3.1 million residents, he helps to oversee billions in government programs.

Starting in 2020, state-mandated disclosures show, Do began receiving outside income through a new law office he created.

On the disclosures for 2021 and 2022, Do selected a box on the forms stating that he received between $100,000 and $1 million per year in income for "law services.”

State law requires local elected officials to disclose all outside income sources of $500 or more per year, which would include specific clients if they pay the official directly. But if the official creates a company — like a law firm — that they control and receive money through, disclosure is only required for clients who paid $10,000 or more.

Do did not disclose in his filings where any of the money paid to his law office came from.

That’s in contrast to other elected officials. For example: When Michelle Steel was a county supervisor, each year she disclosed the names of dozens of clients who paid her husband’s law firm more than $10,000.

Do is the only O.C. supervisor making more than $100,000 per year in outside income who did not make more detailed disclosures about who was paying their company, according to LAist’s review of disclosures.

What’s next

Orange County supervisors are currently in the midst of updating the county’s rules around contracting, including what kinds of conflicts of interest to ban. They’re scheduled to vote on the new contract policy manual on Tuesday, Nov. 28, at their regular Board of Supervisors meeting.

Right now, the county’s conflict of interest rules adhere to the state law definition of “immediate family,” which restricts officials from being involved in steering taxpayer money to their own children who are under 18.

It doesn’t apply when they’re adults.

Do was one of the two county supervisors who oversaw the drafting of the contract policy updates, as an ad-hoc committee member.

The proposed changes to the manual keep the current definition of “immediate family” in place.

Last year, Do ran unsuccessfully for statewide office, seeking to become California’s treasurer who oversees $3 trillion in annual banking transactions and manages over the state’s $100-billion-plus investment pool.

He later opened a campaign fundraising committee for the next state treasurer election, in 2026.