After calculating the 20% limit this money must be earmarked for various accessibility elements serving the Primary Function of the building.
Question: Can the 20% money be spent on the Primary Function area also, since some of the Primary Area needs new accessible features?
Answer: The 20% funds are intended for areas that are not within the Primary Function. Accessible routes from parking lots to the building entrance; accessible route from the entrance to the Primary Function Area; and the toilet rooms serving this Primary Function Area are all typical areas where the 20% funds must be spent.
NOTE: The answers provided are the opinion of the author, and should not be relied upon as ADA interpretations may vary.