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C. ? contracts of employment with persons who perfoi-m any part of the worl< under this instrument, and with all subcontractors and other persons or organizations participating in any part of the work under this instrument. There shall be provisions for a further flow down of such requirements to each sub tier of employees and subcontractors to the extent feasible. 14. DISPUTES During performance of the instrument, disagreements may arise between the Recipient and the GTR on various issues, such as the acceptability of complaints forwarded for approval. If a dispute concerning a question of fact arises, the G/CAO shall be the final authority on the matter and shall prepare a final decision, taking into account all facts and documentation presented. The decision of G/CAO shall be communicated to the Recipient. 15. MAINTENANCE OF RECORDS The G/CAO and the GTR are to maintain all appropriate records relating to the implementation of this cooperative agreement for a period of 5 years for the GTR files and a period of l years for the G/CAO files. The files for the G/CAO are to be kept in a secure place and should be accessible to others only with the G/CAO's permission. After 7 and 5 years respectively, the records may be archived at the records center. 16. COMPLAINANT'S INITIAL CONTACT DATE On December 1, 2005, the U.S. Government Accounting Office (GAO) published an audit report containing findings and recommendations about the manner in which housing discrimination complaints are handled by the Office of Fair Housing and Equal Opportunity (FBEO) and the State and local agencies that investigate fair housing complaints under the Fair Housing Assistance Program (FHAP). GAO's audit reviewed information and data on investigations completed in 2004 and reported the results of test calls that GAO representatives, posing as individuals interested in filing fair housing complaints, made to FHEO regional offices and FHAP agencies in 2005. The GAO report is available on GAO's website at www.gao.gov/new.items/d0679.12df. This supplement to the guidance addresses GAO's finding with respect to the manner in which FHAP agencies enter data in the TEAPOTS system. Specifically, GAO found that FHAP agencies frequently do not enter the actual date on which a complainant first contacted the FHAP agency or FHEO in the Initia] Contact Date field in TEAPOTS. Instead, GAO found that FHAP agencies often entered a later date, such as the date on which the FHAP agency received the case file frorn FHEO or the date on which the FHAP agency received a signed and notarized complaint from a complainant. Agencies need to implements GAO's i•ecommendation that FHAP agencies use the Initial