Bromley Primary Care Trust said it had already compensated one patient after a decision not to fund treatment was overturned at appeal. Wandsworth Primary Care Trust has also received a written request for a refund.
Wandsworth PCT chairman Ian Reynolds told a King's Fund conference: "We're being sent bills by people turned down by exceptional treatment panels and who have then gone private. We're not liable to pay but the reality is that these claims will now end up in court."
Katherine Murphy of the Patients' Association said these claims were "the tip of the iceberg", adding: "The numbers will be far higher once this is more of an open issue and once people know about it.
"People have gone to great lengths, sometimes having to sell their homes to pay for treatments which have been denied to them."
Current rules mean patients cannot top up NHS treatment with expensive private drugs, even if they are not available on the NHS.
A review, by cancer tsar Professor Mike Richards, into restrictions on NHS patients topping up was ordered amid an outcry over some patients being refused care after buying life-prolonging drugs not authorised for NHS use.
Copyright © PA Business 2008
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