We want to find out if other employers with Davis-Bacon contributions to their retirement plans have the same plan design as we do. Our plan is designed so a participant's wages are split into Davis-Bacon and non-Davis-Bacon wages. A regular profit sharing contribution is made that is a flat percentage of non-Davis-Bacon wages. The contribution on the Davis-Bacon wages varies according to the required fringe for each Davis-Bacon job. Do other plans just include the non-Davis-Bacon wages when calculating the profit sharing contribution like we do? Or do you include all wages in that calculation?

We use the participant's total compensation, but any profit sharing allocation is offset by the participant's Davis-Bacon contributions.

I have seen it done both ways, HOWEVER, whatever you come up with needs to pass 401(a)(4). You would need to general test the ultimate allocation based on total compensation.