What is the test for making a restitution order under Section 3651 of the Criminal Code?

Under Section 3651, a restitution order must be limited to "actual damages or loss caused by the offense for which conviction was had." It follows from this provision that there must be some judicial determination of the actual loss suffered by the crime's victims, see United States v. Black, 767 F.2d 1334, 1344 (9th Cir.) (restitution order improper where there was no "plea agreement, judicial determination, or 'consensual means' " fixing amount), cert. denied, 474 U.S. 1022, 106 S.Ct. 574, 88 L.Ed.2d 557 (1985).