First, a local government may determine actual cost pursuant to generally accepted accounting principles. This indicates that a government may establish a cost accounting system associated with providing copies of records, and use that system as a basis for charges for such copies. Many local governments, of course, do not have such cost accounting systems in place, and the demand for copies is unlikely to justify establishing such a system. As long as a government's charges for copies are nominal perhaps up to twenty-five cents per page for photocopies of paper records or the cost of materials for copies of computerized records the lack of any accounting support for charges should not be a problem. Should a local government attempt to impose a charge that significantly exceeds these nominal levels, however, the statutory language suggests it must be able to support those higher charges by a developed cost accounting system.
Governments are most likely to develop such systems for computerized records.
Numerous local governments, for example, account for their centralized computer operations through internal service funds. By using such a fund, the local government can bill the full cost of the computer operations to the departments or agencies that use those services. If the only reference in the statute were to generally accepted accounting principles, a local government that accounted for its central computer operations through an internal service fund would be able to charge citizens for copies of computerized records on the same basis it charged internal users of the system. But the other two elements of the definition of actual costs may make that impossible. The second noteworthy element of the definition is the limitation of charges to direct costs.