How are attorney fees recoverable as damages in a bad faith action?

The recovery of attorney fees as damages under Brandt "must be distinguished from recovery of attorney's fees qua attorney's fees, such as those attributable to the bringing of the bad faith action itself." (Brandt v. Superior Court, supra, 37 Cal.3d at p. 817.) "The fees recoverable ... may not exceed the amount attributable to the attorney's efforts to obtain the rejected payment due on the insurance contract. Fees attributable to obtaining any portion of the plaintiff's award which exceeds the amount due under the policy are not recoverable." (Id. at p. 819.) "If the insured were to recover benefits under the policy in a separate action before suing on the tort, the distinction between fees incurred in the policy action, recoverable as damages, and those incurred in the tort action, nonrecoverable, would be unmistakable." (Id. at p. 818.) But where, as is more commonly the case, the attorney fees claimed as damages are incurred in the very lawsuit in which their recovery is sought, the identification of the allowable fees may be "more sophisticated." (Ibid.)