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09 February 2024 / Dominic Regan
Issue: 8058 / Categories: Features , Procedure & practice , Costs , Personal injury
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Tell, or else: costs & agency fees

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Definitive guidance on the right to a bill breakdown would be useful, says Dominic Regan

Is a paying party entitled to see a breakdown of a bill rendered by a medical reporting agency? An appeal destined for the Court of Appeal this year has been abruptly abandoned.

In the personal injury arena, it is the norm to outsource the exercise of obtaining medical evidence to an agency. In Northampton General Hospital NHS Trust v Hoskin [2023], HHJ Bird heard an appeal in Manchester from the decision of a deputy district judge sitting as a regional costs judge. The dispute concerned two items invoiced by a well-known medical reporting agency, Premex Services Limited. It had billed the claimant’s solicitor for two medical reports and in turn, those solicitors were seeking to recoup the cost from the defendant. One report had cost £5,400 and the other was for £8,775, to both of which VAT was to be added.

‘Reasonable & proportionate’

A request for a simple breakdown of

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