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MOD NIHL Costs: Matrix Damages vs Costs, Bills, PoDs & DA

The matrix speeds damages—it doesn’t fix costs. We draft PD47 Bills/e-Bills, manage PoDs/Replies, secure PoA/DCCs and run to detailed assessment. Military NIHL is outside NIHL FRC. Free first bill.

MoD NIHL Costs — From Matrix Damages to Full Costs Recovery
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MoD NIHL Costs — From Matrix Damages to Full Costs Recovery

Updated: 28/08/2025

The matrix speeds damages. It doesn’t fix your costs. Military NIHL claims sit outside NIHL FRC, so hourly-rate recovery applies. We separate damages from costs, draft PD 47-compliant Bills/e-Bills (Precedent S), manage PoDs/Replies, and push through to detailed assessment where needed.

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What we do (at a glance)

Bills & e-Bills for MOD NIHL with evidential weight (audiology/ENT, service records, disclosure volume)

• Protective settlement wording — “Damages per matrix; costs to be assessed if not agreed”

• PoDs/Replies — defend rates, heavy disclosure, expert necessity and proportionality

• Part 36 strategy — right offer at the right time; 36.17 consequences preserved

• Detailed assessment / enforcement when negotiations stall (PoA, DCCs, hearings)

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Why DMD on MOD NIHL

• Military hearing-loss focus — we understand matrix terms and why they do not govern costs

• Evidence-heavy files handled fast — disclosure logging, exhibit control, and clear necessity narratives

• Separation of issues — we keep damages clean and costs CPR-true

• First file free — prove the value on a live case

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Our process

1. Damages vs costs audit — review the matrix offer; strip out any costs ambiguity

2. Bill & serve — phased Bill/e-Bill + N252 with vouchers and disclosure indices

3. Negotiate — PoDs/Reply with targeted concessions; payments on account where justified

4. Assessment — run to detailed assessment (and enforcement) as needed

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What we need to start

Matrix offer/approval and eligibility proofs (service dates, audiology)

• Time records by phase; disclosure schedules/indices

• Invoices/receipts for audiology/ENT, military records, tracing/restoration and counsel

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Typical outcomes

• Properly separated orders — damages settled; costs to be assessed

• Higher recovery via disclosure-driven necessity and expert evidence

• Faster cash-flow — payments on account and DCCs where defendants miss deadlines

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Pricing & free trial

Free first Bill to settlement. After that, £500 all-in per file (drafting + negotiations + settlement paperwork). 5-day SLA. Costs Lawyer-led. UK-wide, paperless.

CTA: Send us a live MOD NIHL file → info@dmdcosts.co.uk • +44 7724 108 587



FAQs (MoD NIHL)
Does the MoD matrix include legal costs?
No — it’s a damages framework. Costs follow the CPR unless expressly agreed.
Are military NIHL claims in fixed costs?
No — military NIHL is outside NIHL FRC; costs are on the hourly basis.
What if the MoD proposes an “inclusive” figure?
You’re not obliged. We keep damages and costs separate unless a global truly matches the Bill.
Can I claim indemnity costs?
Where the rules allow (e.g., beating your own Part 36 at judgment), we’ll run the appropriate consequences.
Do you handle assessments?
Yes — we prepare bundles, brief counsel, and drive to a payable outcome.
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