We acknowledge the important role of the ASA in representing anaesthetists and contributing to policy discussions affecting both the profession and the broader healthcare system. That role carries a fundamental obligation to ensure that positions are developed transparently, representatively, and independently.

Having reviewed the statement, we raise serious concerns regarding consultation, representation, governance, and the independence of the ASA.

Consultation and Representation

It is not clear what consultation process was undertaken prior to the publication of this statement. Were the more than 100 anaesthetists currently practising at Adeney Private Hospital consulted? If so, do they support the views expressed? If they were not consulted, it is difficult to justify how such a definitive position has been presented as reflective of the broader anaesthetic profession.

The views expressed are clearly not shared by all anaesthetists. As the peak professional body, the ASA has a responsibility to represent the breadth and diversity of its membership. In this instance, it has failed to do so.

It is also noted that, under the ASA’s governance framework for professional documents, the development of position statements is determined through committee processes, with topics identified and progressed by the Professional Issues and Advocacy Committee rather than through a defined membership-wide threshold or formal vote. While this governance structure is understood, it places particular importance on ensuring that appropriate and meaningful consultation occurs where a statement is intended to reflect the position of the profession as a whole. In the absence of such consultation, there is a risk that position statements may not accurately represent the views of the broader membership.

Governance and Conflict of Interest

The credibility of this position is further undermined by the involvement of senior ASA office bearers who are actively practising within the very model being criticised. Dr Grace Gunasegaram, Chair of the Victorian Committee of Management, and Dr Mark Suss, Vice President and Treasurer of the ASA, are both actively involved with Adeney Private Hospital, regularly undertaking clinical lists, and directly benefiting from the very arrangements the ASA is now criticising.

This is not, in itself, inappropriate. However, the absence of clear disclosure in circumstances where senior ASA office bearers are directly engaged in a model under critique raises concerns regarding governance transparency. Without such disclosure, the ASA’s position risks being perceived as inconsistent and lacking impartiality.

It is also noted that senior ASA office bearers connected to the subject matter of the position statement hold direct financial interests in facilities under discussion. This includes Dr Grace Gunasegaram, who holds an investment interest in Adeney Private Hospital. The existence of such interests further reinforces the importance of full and transparent disclosure in circumstances where governance decisions intersect with personal financial interests.

Perceived Alignment with External Stakeholder

It is also not possible to ignore the broader context in which this position statement has emerged.

The ASA’s position appears to align closely with the interests of incumbent hospital providers, particularly Epworth HealthCare. There is a strong concern within the profession that the established relationship between Epworth and Anaesthetic Services (Anaesthetic Group), together with overlapping professional representation within ASA structures - including individuals such as Dr Kaylee Jordan, Chair of the ASA Education Committee and ASA Victorian Education Officer - gives rise to a perception that the ASA’s position may not be entirely independent of these interests.

A further example of this alignment is reflected in recent written submissions concerning Adeney Private Hospital, including commentary attributed to Dr Alan Tse, including his submission to the House of Representatives Standing Committee Inquiry into access to and affordability of medical specialists in Australia on 14 April 2026. That material advances arguments closely mirroring those expressed within PS27, including concerns regarding patient selection, system impact, and sustainability. It is notable that Dr Tse is associated with Anaesthetic Services, a group with established clinical and organisational connections to Epworth HealthCare.

It is also relevant to note that Dr Tse does not practise at Adeney Private Hospital and therefore does not have direct operational or clinical involvement in the model he is describing. While contributions to policy discussion are welcome, the assertions made in this context do not appear to be grounded in direct experience of the facility, and are difficult to reconcile with the observed operation of comparable No Gap models. In addition, the concerns advanced are directed specifically at Adeney, despite the presence of similar No Gap arrangements across multiple private hospitals.

This selective focus raises further questions as to whether the arguments presented reflect a balanced assessment of the model.

In addition, the broader context includes overlapping leadership roles within the sector, including the position of Epworth HealthCare’s Chief Executive, Professor Andrew Stripp, who also serves as Vice President of the Australian Private Hospitals Association. Taken together, these relationships, when considered alongside the consistency of messaging across multiple forums, give rise to a perception that the ASA position may not have developed in isolation, but may reflect perspectives aligned with stakeholders who have a direct interest in the model under consideration. While no improper coordination is asserted, the convergence of these factors underscores the importance of transparency and reinforces the need for disclosure regarding how the position statement was developed.

If so, this represents a concerning departure from the ASA’s role as an independent professional body. It raises the possibility that the organisation’s position may, in part, reflect the perspectives of established operators most exposed to disruption from emerging models such as Adeney, rather than being solely grounded in the independent interests of its members.

Even the perception of such alignment is significant. It undermines confidence in the ASA’s independence and raises a fundamental question - whose interests are being served: Epworth HealthCare, Anaesthetic Services (Anaesthetic Group), patients, or the more than 100 anaesthetists who have not been represented in this position statement?

In this context, any perceived alignment may undermine confidence in the ASA’s independence and judgement.

Clinical and Patient-Centred Considerations

The concerns raised in the position statement regarding patient selection and equity warrant closer examination. The characterisation of these models as “cherry-picking” low-risk patients does not align with established clinical practice. Matching lower-risk patients to appropriately resourced facilities, while directing more complex patients to fully equipped hospitals, is consistent with fundamental principles of patient safety and care delivery and has long underpinned the operation of day surgery and short-stay models across the health system.

Further, the assertion that such models undermine equity within the private system is not substantiated by the current evidence. No Gap arrangements provide a mechanism for reducing or eliminating out-of-pocket costs for eligible patients without removing access for others. Rather than displacing care, these models operate alongside existing hospital services and may reduce overall system cost pressures.

It is also notable that No Gap models are not unique to Adeney.

Similar arrangements are currently in place across multiple private hospitals, including Cabrini Health, Vermont Private, Mulgrave Private and St Vincent’s Werribee, yet these models are not referenced in the ASA position statement.

This selective focus raises a further question as to whether the concerns expressed reflect a narrower response to a single model.

The ASA’s Role and Public Confidence

The ASA exists to advocate for anaesthetists. When it publishes statements that do not reflect the breadth of member views, and which appear aligned with external or institutional interests, it risks eroding trust in its role as a representative body.

Members are entitled to expect independent, balanced, and transparent representation. This statement not only falls short of that expectation, but reads more as a precursor to a media-facing position than a genuinely representative view of the profession. That alone should be of serious concern to all members.

Patient Affordability and the Current Economic Environment

The statement also fails to adequately recognise the current economic reality facing Australian patients. Australia is experiencing a significant cost‑of‑living crisis, with rising healthcare costs placing increasing pressure on patients. Out‑of‑pocket expenses continue to limit access to private care.

In this context, models such as Adeney, which provide No Gap services, offer meaningful and immediate financial relief to thousands of Australians. It is therefore difficult to reconcile how the ASA can raise concerns about affordability and fee pressures while at the same time criticising a model that directly reduces the financial burden on patients.

This contradiction leads to a fundamental question: whose interests is the ASA seeking to protect?

Request for Transparency

In light of the concerns outlined above, there must be clarity regarding how this position statement was developed.

We therefore request full transparency as to:

  • The individuals and committees involved in drafting and approving the position statement
  • The specific attendees and participants involved in any meetings where the position was formed or endorsed
  • Any declared or undeclared conflicts of interest relevant to those involved
  • The nature and extent of consultation undertaken with ASA members, particularly those directly practising within the model under consideration

Given the absence of a defined membership‑wide approval threshold within the ASA’s governance framework, disclosure of this information is essential to allow members to understand how this position has been formed, and to assess whether it appropriately reflects the interests of the profession.

Conclusion

In summary, our concerns are that the consultation underpinning this position is unclear, the views expressed do not reflect the diversity of the profession, relevant conflicts of interest have not been disclosed, there is a credible perception of alignment with incumbent providers and associated networks, and the position does not adequately recognise the patient benefit in the current economic environment.

These issues collectively raise serious concerns regarding the process, balance, and independence of the position statement. The ASA must be able to demonstrate that its positions are developed independently and are not influenced, directly or indirectly, by incumbent providers or associated service groups.

We request clarification regarding the consultation undertaken, the governance processes applied, and how the ASA intends to ensure that future positions are genuinely representative and independently formed.