I try not to add active pressure to the back of temporary soldier beams, below subgrade. AASHTO, 17th Edition, Page 106, Note 1 (below Table 5.6.2A) indicates what active and passive pressures should be applied to a TEMPORARY wall embedded in GRANULAR SOIL or ROCK. Read the note carefully and do only what it says. My experience shows that most engineers never read this note and always add the active pressure. The extra added active pressure doesn't usually hurt the design too bad, but it does hurt. Most soils will arch well enough to not apply the extra active load below subgrade. Also, Kp is usually 10x Ka. Given the "accuracy" (or lack thereof) of the soil properties, why worry a lot about reducing Kp by Ka which is only about a 10% reduction?
HOWEVER, I believe that the newer LRFD AASHTO may not say the same thing. Somewhere, for no apparent reasons, AASHTO "fixed" something that wasn't broken.