QNEC partially used in ADP test - split for general test?

[AndrewZ]

When QNECs are used in the ADP test, I understand that they have to pass 401(a)(4) general testing both alone, and combined with profit sharing (and apparently 410(b) is tested only with them combined).

If you have QNECs allocated that exceed the amount used in the ADP test, do those amounts need to then be carved out and combined with profit sharing for separate 401(a)(4) test (that excludes ADP-tested contributions)? For example, for a Prevailing Wage plan with the P-W contributions classified as QNECs, the amounts exceeding the 10% "disproportionate amount" P-W limit (or the amount needed to make the ADP test pass, if less)? This would be the preferable option, as we are allocating profit sharing to maximize HCEs, so need allocations to NHCEs in the test.

(Assume the plan is using current-year ADP testing, and document seem to have no language addressing this situation, other than P-W contributions up to 10% "can be" used in the ADP test.)

It seems pretty obvious that you would test the "excess" P-W QNECs combined with profit sharing, but this is a rather unusual situation and I'd like to confirm.

Thanks.

[ETA Consulting LLC]

Yes.  When a QNEC is used in ADP or ACP testing, then the portion used cannot be tested with the Profit Sharing Contributions.
 

Good Luck!