No. Private travel purchases are separate from the published government commitments.
Budget for the actual trip without treating it as a program payment
The individual route currently requires US$15,000 nonrefundable processing and the US$1 million post-vetting gift. Use the actual official instructions for any additional charges and assess travel purchase terms separately rather than assuming the government covers them.
Beyond the first payment: a 1% annual maintenance charge, and 5% where the transfer mechanism is used; these are not ordinary initial fees. Identify the provider’s service fee separately from the programme’s published payments. Build a payment schedule from official prompts, not from the passport invoice. The gift is the substantive payment and follows a favourable vetting outcome. The payment must be made by the applicant to the U.S. government, not treated as an investment, escrow contribution, consultant retainer, or substitute for EB-5 capital. The requested amount is a payment by the applicant to the U.S. government; it is not a conventional visa and it is not an investment in a commercial enterprise. Legal fees, and any government charges for the underlying classification as listed in the USCIS fee schedule, sit on top of both.