Client Communication and Post-Settlement

The Settlement Tracker gives you structured, real-time data that can be used to advise clients clearly during a negotiation and to produce a proper record after settlement. This article covers practical approaches to both.

💡 Tip

The more visual you can make things and the more involved you make the client, often the easier the conversations will be. Showing the chart, walking through the gap and midline, and letting the client see the net take-home figures in real time turns an abstract negotiation into something concrete and transparent.

Advising During Negotiations

Explaining Take-Home Amounts

When your client receives an offer, the most important question is usually "What do I actually get?" The Take-Home Analysis section answers this directly by deducting all recorded costs and expenses from the gross offer.

Before presenting figures to your client:

Confirm that all costs in the Costs & Expenses panel are up to date -- legal fees, barrister fees, Medicare notice, medical records, and any other outlays
Scroll to the Take-Home Analysis to see the net-to-client at the current plaintiff position, defendant position, and midline
Use the Quick Calculator to model specific amounts your client might consider as a counter-offer

💡 Tip

If your client asks "What would I get if we settled at $X?", type the amount into the Quick Calculator and read the net figure back immediately. This avoids mental arithmetic under pressure and ensures expenses are not overlooked.

Using the Gap and Movement Data

The position cards and movement info bar help frame the negotiation for your client:

Gap -- shows how far apart the parties remain. A narrowing gap can encourage a reluctant client to make further concessions
Midline -- provides a natural reference point for "splitting the difference" discussions
Movement tracking -- shows whether one party is making proportionally larger concessions. If the defendant has moved significantly while the plaintiff has barely budged, this can be a persuasive data point when advising your client to reciprocate

Showing the Chart

The negotiation chart provides a visual summary that many clients find easier to understand than raw numbers. The converging lines show the negotiation trajectory at a glance. Sharing your screen or turning your laptop to show the chart can be an effective way to illustrate progress during a mediation -- clients can see at a glance where things stand, how far the parties have moved, and what the trajectory looks like without needing to parse a list of figures.

Defendant Mode

If you are acting for the defendant or an insurer, the tracker operates in Defendant mode. Instead of showing net-to-client figures, it shows total settlement cost -- the settlement amount plus your client's own costs (legal fees, expert reports, investigation costs, and any other items in the Costs & Expenses panel).

This is useful for advising insurers or self-insured defendants on total exposure at each settlement figure, and for comparing the cost of settling against the cost of proceeding to hearing.

After Settlement

Recording the Agreement

Once the parties agree on a figure, mark the accepted offer in the Offers table by clicking the green tick icon. The tracker displays a green confirmation banner showing:

The agreed settlement amount
The net to client after expenses (Plaintiff mode) or total cost including defendant's costs (Defendant mode)

This remains visible on the tracker and is included in the exported report.

Final Documentation

After the mediation or settlement conference:

Update expenses with any final confirmed figures (e.g., the actual Medicare Notice of Charge amount, confirmed counsel fees)
Add notes to the agreed offer if there are conditions (e.g., "Plus costs as agreed", "Subject to Deed of Release")
Export the session by clicking Download DOCX -- this produces a formatted Word document containing the full offer history, negotiation summary, expenses, and agreed settlement breakdown
Save the exported document to your practice management system or document management system as a permanent file note

ℹ️ Note

The exported report is very helpful to then populate your advice to the client at the end of the negotiations. It includes a complete breakdown of the agreed settlement -- gross amount, itemised expenses, and net to client -- giving you a ready-made structure for your post-settlement correspondence.

Reporting to Clients

The tracker data provides a clear structure for your post-settlement letter or email to the client:

The agreed amount and what the client will receive after deductions
A breakdown of each expense (legal fees, disbursements, Medicare, etc.)
The net amount payable to the client

This level of detail helps manage client expectations and satisfies your obligations to provide clear costs disclosure.

Next Steps

Exporting and Sharing -- details on the DOCX export and how to use it