Earlier this week, the Office of Federal Contract Compliance Programs (“OFCCP”) announced that it entered into a conciliation agreement with Humana Inc. (“Humana”) to resolve allegations that Humana paid hundreds of women at its Louisville, Kentucky headquarters less than their male coworkers.

OFCCP asserts that in 2011 and 2012, Humana paid 753 women in consulting, project manager, and manager positions less than similarly situated men.  Under the terms of the conciliation agreement, Humana will pay $2.5 million in back pay and interest.  Humana will also institute certain pay adjustments and review its compensation practices to ensure compliance going forward.

The Humana settlement reflects that, under the Trump Administration, OFCCP is continuing to focus on equal pay issues, specifically systemic pay discrimination.  As a result, it is more important than ever for contractors to undertake a privileged self-audit of their compensation and of policies that may contribute to compensation disparities, including hiring practices, training and promotion opportunities, and performance management.

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