Actual costs includes both direct and indirect costs, exclusive of management overhead.
Efficiency to the Government processing means the ability of the United States to process an application with a minimum of waste, expense and effort. The term does not include an act made by mistake or inadvertence. The term includes actions taken with criminal or malicious intent. A consistent pattern of trespass may be sufficient to establish the knowing or willful nature of the conduct, where such consistent pattern is neither the result of mistake or inadvertence. Conduct which is otherwise regarded as being knowing or willful does not become innocent through the belief that the conduct is reasonable or legal.