Prevailing Wage Credit for HRA Audit Expenses

A construction company subject to prevailing wage laws sponsors an HRA funded via a trust. Contributions are made to the trust for each hour worked, and the trust reimburses participants when they incur medical expenses. The trust also pays Plan audit fees and legal expenses. The question is whether the company can take full prevailing wage credit for all contributions to the trust if a portion of those contributions are used to pay Plan audit fees and legal expenses rather than provide direct reimbursement benefits. Thanks for any help.