Months before prosecutors charged a former nonprofit executive with criminal misappropriation, an internal county review flagged the need for stronger oversight of its many contractors – and red flags with a former contractor now embroiled in scandal.
Late last year, the county’s Health and Human Services Agency finalized a special review of the Harm Reduction Coalition of San Diego to find out whether the nonprofit was complying with its county contracts.
The review dated Oct. 12 concluded there were several “opportunities for improving internal controls within County of San Diego operations.”
Also among its findings: The Harm Reduction Coalition took months to notify the county of a non-fatal October 2024 overdose at the nonprofit’s office, took a county-funded vehicle to Mexico, inappropriately co-mingled personal and business expenses and allowed its chief operating officer to manage her own subcontract.
Harm Reduction Coalition CEO Tara Stamos disputes many of the report’s conclusions, arguing that it includes inaccurate and incomplete information.
County spokesperson Tim McClain said the county acted rapidly on its findings.
“The county’s June 2025 investigation resulted within 30 days in suspending, then closing the two contracts and referring the matter to the district attorney,” McClain wrote in an email. “The county is also reviewing its internal processes with support from an outside auditor.”
The inquiry was triggered by early June complaints from former Harm Reduction Coalition COO Amy Knox about issues with the nonprofit she had until recently helped lead and from subcontractor A New Path, which had gone months without being paid for its work.
Four months after that review and seven months after the county cancelled its Harm Reduction Coalition contracts, District Attorney Summer Stephan’s office charged Knox with felony misappropriation and estimated that she spent at least $210,000 in public funds on everything from plastic surgeries to family vacations.
Knox’s complaints to the county came around the same time Stamos said she began reporting her own concerns about potential embezzlement to Stephan’s office, a report that eventually led to a criminal investigation that for now appears focused on Knox. The county says an unidentified county official also “referred information” to the District Attorney’s Office on June 23. The complaints came years after Knox’s 2015 guilty plea for embezzling more than $500,000 from two former employers.
Voice of San Diego obtained the county’s review of the situation after a public-records request that the county initially denied. The county declared the document was protected by attorney-client privilege though the review was conducted by the county Health and Human Service Agency’s Business Assurance & Compliance Office rather than an attorney providing legal advice. The county released the review after Voice disputed the county’s claim of attorney-client privilege and threatened to sue.
Here’s a breakdown of the report.
The lead-up: On June 5, 2025, Knox filed a complaint with the county’s Office of Ethics and Compliance alleging “unethical business practices, hostile work environment, and retaliation” at the Harm Reduction Coalition – and that she had not been paid for her work in May 2025. She also notified the nonprofit’s county contract administrator that she had stopped working for the Harm Reduction Coalition about two weeks earlier and no longer had access to documentation to submit invoices to the county.
Christy Carlson, director of business assurance and compliance in the county’s Health and Human Services Agency, wrote that the contract administrator and Behavioral Health Services Department managers contacted her office to seek guidance.
“They had concerns that (Knox) had previously been the sole individual at HRCSD who was able to provide responsive information regarding organization operations as well as documentation related to invoice submissions to the county,” Carlson wrote.
A few weeks later, A New Path – a nonprofit partner under the Harm Reduction Coalition’s contract to distribute overdose reversal drugs – told the county it had not been paid for its work in February or March.
Allegation 1: A vehicle purchased though the county’s naloxone distribution contract was used for a trip to Mexico.
Carlson wrote that the county inspected two county-funded Harm Reduction Coalition vehicles and found an insurance certificate issued in Mexico. The county asked Stamos whether she had used the county-funded vehicles for purposes other than its two county contracts. Carlson said Stamos acknowledged she had driven one vehicle to Mexico without county permission after being shown the insurance paperwork.
The county decided this allegation was substantiated.
Stamos claims the county knew of and supported her efforts to provide naloxone training in Mexico.
“I told them I was going to Mexico on a phone call,” Stamos said. “There was a phone call made.”
Allegation 2: The Harm Reduction Coalition CEO regularly distributed naloxone across the border using a county vehicle or her own vehicle.
Carlson noted Stamos’ Facebook posts and a Mexican news article describing her as the “naloxone fairy godmother.” She wrote that the county made unannounced site visits to the Harm Reduction Coalition’s office in part to view stored naloxone and inventory reports showing drugs received and deployed.
Carlson wrote that the county found no evidence of supplies coming from entities other than the county at the office and that outbound inventory logs didn’t clarify if naloxone was distributed in Mexico. She said Stamos said she had not taken county-funded naloxone to Mexico but “was unable to provide information related to where she obtained that inventory other than stating that many people provided supplies but wanted to remain anonymous.”
The county decided there were inadequate internal controls for county naloxone inventory but couldn’t verify whether there was “improper distribution in Mexico.”
Stamos said she told the county she believed naloxone inventory reports should be more detailed to allow for more clarity and that she distributed donated naloxone in Mexico from suppliers other than the county. She also said the county’s unannounced visit came on a day she was not in the office and that the county failed to ask her to share more details on alternate locations and suppliers.
Allegation 3: A county-funded vehicle had UC San Diego plates from an RV that the CEO improperly stored outside her home.
During the county’s initial review, county investigators came across a photo of a county-funded van that had a license plate belonging to a motor home registered to the Regents of the University of California.
Later, when the county was retrieving Harm Reduction Coalition vehicles tied to its contract, it found license plates shown in that picture inside one of its vans. Carlson wrote that the county asked Stamos about this and she confirmed the plates belonged to a UCSD vehicle but wasn’t sure why they were inside a county van. She said a UCSD professor had given her the plates and that she had parked a UCSD motor home loaned to her for a research collaboration with the university outside her former El Cajon home.
Then, according to Carlson, Stamos said two homeless residents “had been living in the vehicle, and that she did not know where they had taken it.”
In October, the county confirmed with a UCSD fleet manager that the vehicle was reported stolen on July 15.
The county decided the Harm Reduction Coalition had improperly possessed government property but could not say for sure whether the UCSD license plates were misused.
Stamos said UCSD had allowed her to store the aging UCSD RV at her El Cajon home because it was fenced in and that she was not sure why UCSD license plates were placed on a county vehicle.
She said she allowed two homeless San Diegans who were grieving the loss of a loved one to live at her home after she moved elsewhere. Then she said she was shocked to return home one day to find the RV missing after she informed the homeless couple that she was going to be ending her lease for the property, which would force them to relocate.
A UC San Diego spokesperson confirmed last Thursday that the missing vehicle still hasn’t been recovered.
Allegation 4: Knox “inappropriately entered into a contract” with a naloxone machine vendor.
Stamos alleged that Knox brokered a contract with SMRT1 Health Solutions and the Harm Reduction Coalition to lease four naloxone vending machines to deploy in the county. The county confirmed the nonprofit leased four machines from SMRT1 in November 2023 and the county’s contract administrator had approved the leases before they took effect. Knox’s LinkedIn page showed she began working for SMRT1 in June 2025, but the county didn’t contact the company to confirm details. Knox had told the county in June about her work with SMRT1 and “sought to establish a relationship directly between SMRT1 and the county for the four vending machines that had been leased by HRCSD.” The county decided against taking over the lease and removed the vending machines.
The county decided it was “inconclusive” whether Knox had a conflict of interest tied to the SMRT1 vending machines.
Stamos is adamant there was a conflict. She said Knox approved her consulting company as a contractor without her knowledge and believes she was directly benefiting from the SMRT1 contract too.
“She approved her own contract and approved it as my subcontractor,” Stamos said.
Allegation 5: The Harm Reduction Coalition took months to notify the county of a non-fatal overdose that happened at its office, did not require a drug-free work environment despite contract mandates and improperly handled drugs at its office.
Knox claimed Stamos didn’t mandate a drug-free work environment and that a staffer took a drug sample tied to the nonprofit’s county drug checking contract and overdosed in the office in October 2024.
“The individual was revived, however, HRCSD did not notify (the county) of the serious incident until January 2025, and information related to the individual obtaining the drug from the samples obtained under contract was not included on the incident report,” Carlson wrote.
Carlson said the county was unable to confirm details as the employee no longer worked at the nonprofit and the person who corroborated Knox’s claims was related to her. She also wrote that when the county visited the nonprofit’s office, it found no drug samples there and could not “test for adequacy.”
The county decided the Harm Reduction Coalition inadequately reported a serious incident but couldn’t confirm onsite drug use or improper storage of drug samples.
Stamos said she learned of the incident several weeks after it happened and immediately ordered her staff to report it to the county once she became aware of it. Stamos said the staffer had been struggling after witnessing a traumatic accident on his first day with the Harm Reduction Coalition and was tempted to use a small drug sample as he transferred it to be sent off for further testing when he was left alone.
“The storage of the drug wasn’t the issue,” Stamos said. “It was that it was being transferred from one envelope to another.”
Stamos said Harm Reduction Coalition staff got more training and instituted protocols to ensure employees weren’t left alone during future drug sample transfers.
Allegation 6: The Harm Reduction Coalition had “poor financial controls” and didn’t properly split duties to minimize risks.
Carlson wrote that Knox and Stamos both alleged there were “improper personal expenses” in the Harm Reduction Coalition’s bank account. The county reviewed bank statements and copies of the nonprofit’s QuickBooks general ledger from Knox plus invoices submitted to the county.
The county wrote that “numerous charges that appeared to be personal” when it reviewed bank statements and QuickBooks ledgers – and that bank statements included deposits from entities other than the county.
“Our review did NOT find any instances where personal charges appeared to have flowed to invoices submitted to the County either directly or through indirect charges,” Carlson wrote. “However, it was concerning and notable that the lack of internal controls at HRCSD allowed for personal and business expenses to be co-mingled, including apparent personal loans from (Knox) to the HRCSD bank account.”
The county reviewed documentation tied to the Harm Reduction Coalition’s two contracts and reported challenges validating some information. But Carlson noted the county has set reporting thresholds low to encourage the distribution of naloxone and use of the drug checking services.
Carlson also flagged that Knox had “responsibility for executing her own subcontract” which she said raised “concerns related to HRCSD status as a California non-profit agency.”
Also: “Furthermore, when interviewing (Stamos), she indicated that she had never read the actual contracts between HRCSD and (the county) until July 2025 when (the county) informed her of the suspension, and subsequent cancellation,” Carlson wrote.
Stamos said she has read the county contracts but had tried to convey that she never sat down to read them in one sitting. She faults Knox, who she said oversaw financial work for the nonprofit, for the issues the county flagged.
McClain, the county spokesperson, said this part of the review was limited by the county’s ability to access personal finance records.
“Determining responsibility for specific expenses is outside the county’s authority,” McClain said. “It is appropriate to await the outcome of the DA’s investigation and our audit.”
The County’s Advice to Itself: Carlson wrote that “the real or perceived conflict of interest related to (Knox) in her role as chief operation officer, as a subcontractor, responsible for overseeing her own contract” should have been noted by the contract administrator as an internal control requiring improvement.
Notably, an April 2023 county audit of the Harm Reduction Coalition flagged the fact that Knox was an accounting subcontractor who also was “listed as the contractor’s grant administrator, treasurer, and a board director” and ordered the nonprofit to develop and implement procedures to “ensure segregation of duties and conflicts of interest are addressed.”
An August 2023 corrective action follow-up letter described this and other internal control changes as “accepted and complete.”
McClain said the county confirmed that the Harm Reduction Coalition made changes including “adding segregation of duties, using a bookkeeping agency and removing Amy Knox from board positions.”
Yet Knox appeared to still play dual roles as both the COO and a subcontractor via her own company, The Knox Consultants.
In the 2025 review, Carlson also wrote that there were several instances where county staff signed off on Harm Reduction Coalition purchases that appeared to be “excessive and not a prudent use of funds.”
For example, the nonprofit bought Mercedes Benz vans that the county estimated cost $80,000 rather than Ford Sprinter vans that cost about $60,000. The SMRT1 vending machines leases also cost $30,000 a year compared with standard machines that cost $8,000.
“Current processes for due diligence prior to authorization of expenditures should be reviewed to ensure funds are being handled with care,” Carlson wrote.
Carlson also suggested the county craft future contracts to allow for easier, more accurate validation of work.
She raised concerns about unpaid Harm Reduction Coalition subcontractors too.
“Reports that subcontractors were not being compensated timely, and in fact several subcontractors are still unpaid for services provided under the contract illustrate the importance of contractor accounts payables related to county contracts requiring regular monitoring, especially for smaller contractors,” Carlson wrote.
Months later, the subcontractors are still waiting to be paid.
Stamos faulted Knox for the alleged conflicts of interest, excessive spending and payment issues with its nonprofit partners.
She also accused the county of not doing more to help before and after she started to try to contact the District Attorney’s Office in late May to report suspected embezzlement. She said she started to raise concerns about Knox with the county in April and also found the county ill-equipped to offer guidance on unique contracts like hers.
“I had expected more from the county,” Stamos said. “They knew I had asked for all these things. I asked for guidance and I didn’t get it.”