The published cost is the gift to the U.S. government plus a processing fee, in the amounts shown on the official program page at the time of payment. A gift is spent, not invested; it is not returned, does not earn a return and must not be compared with EB-5 capital that is placed at risk and may be recovered.
Spent money and at-risk money are not the same line
The builder's error is arithmetic as much as legal: he has compared the Gold Card figure with an EB-5 amount as if both were prices for a similar product. EB-5 capital is invested in an enterprise, must remain at risk, must create ten jobs and may be returned under the project's terms after the sustainment period, and it is not a government payment at all. The Gold Card gift is a transfer to the U.S.
government with no return and no ownership; the processing fee is likewise spent. Both figures should be taken from the official page on the day of payment, and the applicant should record that they were verified then. Beyond those, the builder's actual costs include state contractor licensing, bonding and insurance, US company formation, accounting and tax advice on becoming a US resident, and relocation.
None of those are program fees. The only bill he should never pay is one presented by someone who is not the official channel; there is no refund path for a gift that never reached the U.S. government.