## Aura Aged Care

Part 1: The New Market Landscape: Strategic Analysis of the Aged Care Act 2024 1.1 Executive Overview: The Rights-Based Revolution as a Market Opportunity 1.2 Provider Obligations (Chapter 3, Part 4) as a B2B Sales Funnel 1.3 The Digital Gateway: Navigating 'Aged Care Digital Platform Operator' Obligations (Chapter 3, Part 6) Table 1: Aged Care Act 2024 Compliance & Opportunity Matrix Part 2: Integrated System Architecture & Regulatory Pathway 2.1 Integrated Architecture: The "Aura Home" Platform 2.2 Regulatory Pathway 1: "Aura Clinical" as Software as a Medical Device (SaMD) 2.3 Regulatory Pathway 2: "Aura Place" as Assistive Technology (AT) 2.4 IMPORTANT RISK & PIVOT: The HBOT Co-operative (Hyperbaric Chamber) Table 2: Integrated System Architecture & Regulatory Classification Part 3: Corporate, Legal, and Tax Structure (The Three-Vehicle Model) 3.1 Vehicle 1: "Aura Health-Tech Pty Ltd" (The Core Commercial Entity) 3.2 Vehicle 2: "Aura Access Co-operative Ltd" (The Access & Scaling Vehicle) 3.3 Vehicle 3: "GAJRA Earth DAO" (The Philanthropic & Research Arm) Table 3: Comparative Legal & Tax Structure Analysis Part 4: Phased Commercialisation, Partnership, and Funding Roadmap 4.1 Phase 1: Validation (Years 1-3) - Focus: "Aura Clinical" & Dementia 4.2 Phase 2: Pilot Deployment (Years 2-4) - Focus: "Aura Place" & AT-HM 4.3 Phase 3: Scaled Rollout (Years 4+) - Focus: "Aura Access" & Investment Table 4: Phased Funding & Partnership Roadmap (2025-2030) Works cited

## Part 1: The New Market Landscape: Strategic Analysis of the Aged Care Act 2024

## 1.1 Executive Overview: The Rights-Based Revolution as a Market Opportunity

This advisory report outlines a comprehensive commercialisation and regulatory strategy for the proposed suite of digital twin and wellness technologies. The analysis is anchored in the new legal landscape defined by the Aged Care Act 2024 (the Act), which commenced operation on 1 November 2025.

The foundational thesis of this plan is that the new Act is not a regulatory burden; it is the single greatest market opportunity for the proposed systems. The Act codifies a profound philosophical shift away from a provider-centric, compliance-led model to a person-centric, rights-based system. This change creates an immediate and urgent market need for technologies that can deliver, measure, and prove the new, more abstract concepts of "wellbeing" and "choice" that are now law.

The Act's objects (Section 5) explicitly target "active, self-determined and meaningful lives," "choice and control," and "high quality care". The new "Statement of Rights" (Section 23) is the central pillar of the legislation. The proposed "Aura of Intelligence" and "Sovereign Space Builder" platforms are purpose-built to deliver on these new, mandatory rights:

- Right 23(1) (Autonomy): An individual has a right to "exercise choice and make decisions that affect the individual's life". The proposed digital twin platforms are the operating system to enable and record this choice.
- Right 23(3) (Quality): An individual has a right to "quality and safe funded aged care services". The platforms provide the longitudinal data to monitor and validate this standard.
- Right 23(4) (Safety): An individual has a right to "be free from all forms of... neglect, coercion, abuse". The "Digital Twin of place" can function as an advanced monitoring and alert system to help prevent neglect and reportable incidents.

The projects' stated goals-to "heal people" and "help mental health of carers and patients"-are perfectly aligned with this new legal definition of "high quality care" (Section 20). This section now legally requires "supporting the improvement of the individual's wellbeing, independence, autonomy and physical and cognitive capacity through reablement approaches" [, Sec 20(c)(v)].

Therefore, the "Aura of Intelligence" and "Sovereign Space Builder" systems are not merely wellness products; they are reablement engines . The core strategic narrative for this venture is that this integrated platform provides the only practical, scalable, and auditable way for aged care providers to prove they are meeting the new, abstract, and legally binding obligations of the Aged Care Act 2024 .

## 1.2 Provider Obligations (Chapter 3, Part 4) as a B2B Sales Funnel

The new, stringent "Conditions on provider registration" (Chapter 3, Part 4) create the primary business-to-business (B2B) sales driver for the platform. Aged care providers are the channel to the end-user (the care recipient). The proposed platform is the tool they could acquire to ensure their own compliance and business continuity.

The platform provides a direct, technical solution to the following new mandatory conditions:

- Solution for Section 146 (Aged Care Quality Standards): Providers could comply with the strengthened Quality Standards. These standards are no longer a simple checklist. The "Aura of Intelligence" digital twin provides the longitudinal data and reablement pathways to demonstrate continuous improvement in a resident's quality of life, directly addressing this core compliance need.
- Solution for Section 164 (Incident Management): Providers have a mandatory

condition for "Incident management". The "Sovereign Space Builder" , as a "Digital Twin of place" with environmental and biometric sensors, can act as a predictive incident management system (e.g., fall prevention analytics, monitoring for signs of neglect, alerts for environmental hazards).

- Solution for Section 165 (Complaints, feedback and whistleblowers): The Act (Section 23(9)) grants individuals the right to "make complaints... without fear of reprisal". The platform can provide a direct, private, and secure communication channel between the resident or their "supporter" (Part 4) and high-level provider management, bypassing local gatekeepers and creating a transparent complaints mechanism that satisfies Section 165.
- Solution for Section 158 (Advisory body requirements): Providers could now establish and engage with a "consumer advisory body" [, Sec 158(4)]. The platform is the digital infrastructure to run this body efficiently, enabling communication, feedback, and governance.

The most compelling driver for B2B adoption is the new "Statutory duty and compensation pathway" (Chapter 3, Part 5, Sections 179-186). This new pathway, particularly Section 186 ("Compensation orders"), allows the Federal Court to order an entity to compensate an individual for "serious injury or illness" resulting from a provider's contravention of their duty (Section 179).

This creates an enormous, direct financial and legal risk for providers. The "Sovereign Space Builder" , by monitoring the "Digital Twin of place," is no longer a 'nice-to-have' wellness app. It is an important risk mitigation and liability management tool. The sales pitch is transformed from a soft "improve wellbeing" proposition to a hard, high-urgency B2B imperative: "Prevent the compensation order that could result in millions in liability."

## 1.3 The Digital Gateway: Navigating 'Aged Care Digital Platform Operator' Obligations (Chapter 3, Part 6)

An important and immediate legal warning could be issued. The Act creates a new regulated class of entity: the "aged care digital platform operator" (Chapter 3, Part 6, Sections 187-189).

An "aged care digital platform" is defined in Section 187 as an "online enabled application, website or system" that "acts as an intermediary" between entities seeking services and entities providing them, and "processes, payments" referable to that function.

The conceptual model for the "Sovereign Space Builder," with its "L1 Neighbour Mesh" (e.g., trading basil for sourdough) and "Fractal Ark" , could inadvertently trigger this classification. If the platform is used to facilitate payments or act as an intermediary for individuals to find carers, or for providers to offer services to the public through the app, it will be captured by this definition.

The consequences are significant. As a platform operator, the entity would have a strict legal "Duty" under Section 188 to check and display the registration status, banning orders, and other prescribed information for every entity offering services on the platform. Furthermore, Section 189 would require the platform to implement its own separate complaints and incident management systems. This represents a massive compliance and operational burden for a pre-revenue startup.

Therefore, the initial business model could be structured to avoid this classification. The entity is not an "intermediary" (like an Uber for aged care). The entity is a B2B software vendor . The "Aura Home" platform (the integrated system) is a tool sold or licensed to a Registered Provider

(e.g., Bolton Clarke). That provider then uses the tool to manage their own clients and their own workforce. This structure places the provider obligations (Chapter 3, Part 4) squarely on the provider (who is already subject to them) and allows the technology company to avoid the platform operator obligations (Chapter 3, Part 6) entirely.

Table 1: Aged Care Act 2024 Compliance & Opportunity Matrix

| Aged Care Act 2024 Provision            | Guidance/Risk for Providers                                                                             | "Aura Home" Platform Solution                                                                                                                                                                                                |
|-----------------------------------------|--------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Sec 20: Meaning of "high quality care"  | Could prove delivery of "reablement approaches" and improvement of "wellbeing, independence, autonomy". | "Aura Clinical" Twin: Provides longitudinal data on cognitive/physical capacity, tracking reablement outcomes and proving delivery of "high quality care."                                                                   |
| Sec 23(1): Statement of Rights          | Could uphold the legal right to "independence, autonomy, empowerment and freedom of choice".            | "Aura Place" Platform: Provides the in-home interface for the user to make and log daily choices (food, activities, environment), creating an audit trail of autonomy.                                                       |
| Sec 146: Condition: Quality Standards   | Could demonstrate compliance with strengthened Aged Care Quality Standards.                             | "Aura Clinical" Dashboard: Aggregates QoL and reablement data into reports aligned with Quality Standards, demonstrating continuous improvement.                                                                             |
| Sec 164: Condition: Incident Management | Could have a robust system for managing and reporting incidents.                                        | "Aura Place" (Place Twin): Functions as a predictive incident system. Uses sensors to generate alerts for fall risks, environmental hazards, or neglect indicators.                                                          |
| Sec 165: Condition: ComplaintsMust      | manage complaints transparently and without reprisal [, Sec 23(9)].                                    | "Aura Home" Platform: Provides a secure, direct-to-management digital complaints channel for residents and their registered "supporters".                                                                                    |
| Sec 186: Compensation Pathway           | New, significant legal and financial liability for "serious injury or illness" from a breach of duty.  | "Aura Place" (Place Twin): Functions as an important risk mitigation tool. Its predictive alerts and monitoring provide a verifiable record that the provider took active steps to prevent harm, mitigating Sec 186 liability. |

## Part 2: Integrated System Architecture & Regulatory Pathway

## 2.1 Integrated Architecture: The "Aura Home" Platform

To execute this strategy, the various concepts could be consolidated into a unified, two-tiered product suite designed specifically for the aged care market. This integrated "Aura Home" platform provides a coherent go-to-market architecture.

- Product 1: The "Aura Home" Platform (The Core System)
- Component A: "Aura Clinical" (Body/Mind Twin): This is the clinical application of the "Aura of Intelligence". It serves as the high-level clinical dashboard for providers, allied health professionals, carers, and (with consent) family. Its function is to map narrative, biometric, and carer-reported data to validated clinical outcomes, such as the Dementia Outcomes Measurement Suite (DOMS).
- Component B: "Aura Place" (Place Twin): This is the integration of the "Sovereign Space Builder" and "Kitchen Mate". This is the in-home "Assistive Technology" interface for the care recipient. It is focused on autonomy, environmental control, nutrition, reablement, and safety.
- Product 2: The "Aura Access" Wellness Service (The Add-On)
- Component C: The "Aura Capsule" (HBOT): This is the physical Hyperbaric Oxygen Therapy (HBOT) device. It is not sold as a standalone product but is delivered as a wellness service. It is funded and managed by the "Aura Access Co-operative" and placed within partner provider facilities.

## 2.2 Regulatory Pathway 1: "Aura Clinical" as Software as a Medical Device (SaMD)

The "Aura Clinical" platform , especially when applied to dementia care for purposes of monitoring, assessment, and intervention, is unequivocally a medical device under Australian law.

- Classification: The system will be regulated by the Therapeutic Goods Administration (TGA) as Software as a Medical Device (SaMD) . It also functions as a Clinical Decision Support System (CDSS) .
- Risk: The proposed Class IIa risk classification is appropriate. This classification is justified because the system is intended to inform clinical decisions (e.g., by correlating data and suggesting interventions) rather than driving them through automated diagnosis, which would attract a higher risk class. The TGA is actively reviewing AI-based medical devices and digital mental health tools in 2025, making a rigorous and transparent regulatory process non-negotiable.
- Mandatory Requirements:
1. Quality Management System (QMS): The entity could establish and maintain a QMS compliant with ISO 13485:2016 (Medical devices - Quality management systems). This is a foundational R&D cost and a prerequisite for TGA approval.
2. Technical Documentation: A complete technical file is required, detailing the
- software architecture, algorithms, risk management (ISO 14971) , and robust cybersecurity protocols.
3. Clinical Evidence: The phased clinical trial protocol (Feasibility, Pilot, and RCT) is the only pathway to generate the required clinical evidence of safety and efficacy for the TGA submission.
4. TGA Submission: A formal application could be made to the TGA for inclusion of the SaMD on the Australian Register of Therapeutic Goods (ARTG).

## 2.3 Regulatory Pathway 2: "Aura Place" as Assistive Technology (AT)

This pathway represents the fastest route to initial, government-funded revenue. The new "Support at Home" program, which commenced on 1 November 2025, fundamentally changes the funding landscape for assistive technology.

- The Opportunity: The new Assistive Technology and Home Modifications (AT-HM) scheme creates a separate funding pool for AT. This funding is distinct from the recipient's main quarterly budget for ongoing services, meaning they do not have to choose between care and technology.
- Funding Tiers: The AT-HM scheme provides funding of up to $15,000 for assistive technology and a separate pool of up to $15,000 for home modifications over a 12-month period.
- Positioning the Product: The "Aura Place" system (comprising "Sovereign Space Builder" and "Kitchen Mate" ) can be supplied under this scheme. Its components map directly to the scheme's inclusions:
- The platform (tablets, software, smart-home integration) constitutes "cognitive support tools," "digital calendars," and "memory aids for dementia care".
- The sensors used to build the "Digital Twin of place" (e.g., fall detectors, door sensors, smart-stove cutoffs) are "safety tools" and "personal alarms".
- The entire system's purpose is to promote "wellness and reablement" and support "older people to maximise their independence".
- Go-to-Market Action: The entity could register as a Registered Provider under Chapter 3, Part 2 of the Aged Care Act 2024 . The Department of Health is currently offering training for new providers to understand their responsibilities under the Support at Home program. Once registered, the entity can be selected by any care recipient who has an AT-HM assessment to provide and be paid for the "Aura Place" system.

## 2.4 IMPORTANT RISK & PIVOT: The HBOT Co-operative (Hyperbaric Chamber)

The plan for a home-based HBOT co-operative presents an important, project-ending flaw. The Therapeutic Goods Administration (TGA) has issued explicit safety alerts to the public warning: " Do not purchase a hyperbaric chamber for use at home ". The primary, severe risk is fire in an oxygen-enriched environment. HBOT devices are high-risk medical devices intended for use only by "qualified healthcare professionals in clinics that are properly equipped and authorised".

The original plan to use co-operatives to place HBOT devices in private homes is therefore in direct violation of TGA safety guidance. This approach is unsafe, uninsurable, and legally indefensible. Pursuing it would jeopardise the entire "Aura" project, as regulators (TGA) and potential partners (e.g., Bolton Clarke, UQ) will associate the legitimate SaMD (Aura Clinical) with this non-compliant, high-risk hardware.

The project's goal (reducing cost from $100/hr to $10-$50/hr) [User Query] is valid. The mechanism (a co-operative to socialise cost) is also valid. The location (home use) is the fatal flaw.

A strategic pivot is therefore required: keep the goal and the mechanism, but change the location.

The "Aura Access Co-operative" will be restructured as a B2B2C (Business-to-Business-to-Consumer) model:

1. Partnership: The Co-operative (Vehicle 2, see Part 3) will partner with Registered Providers (e.g., BlueCare, Bolton Clarke) and clinical partners.
2. Funding: The Co-operative will use its member-funded microfinance model to finance the capital expenditure for TGA-approved, medical-grade "Aura Capsule" devices.
3. Deployment: These devices will be physically installed inside the provider's residential aged care homes or in their accredited community clinics, not in private homes.
4. Compliance: This model aligns perfectly with TGA guidance ("used by qualified healthcare professionals") and Medicare rules, which generally provide rebates only for HBOT in a "comprehensive hyperbaric medicine facility".
5. Value Proposition: Co-op members (who can be the provider's residents, their families, or community members) gain access to the therapy at the target low-cost rate. The provider gains a high-value, marketable wellness service to prove its "high quality care" (Section 20) guidance with zero capital outlay. This pivot makes the HBOT model safe, legal, and commercially brilliant.

Table 2: Integrated System Architecture & Regulatory Classification

| Product Component   | Core Technology                                     | Intended Use (Aged Care)                                             | TGA Regulatory Class                                    | Funding Pathway                                  |
|---------------------|-----------------------------------------------------|----------------------------------------------------------------------|---------------------------------------------------------|--------------------------------------------------|
| "Aura Clinical"     | AI/LLM Digital Twin (Software)                      | Clinical decision support for dementia; QoL & reablement tracking.   | SaMD (Class IIa)                                        | MRFF Grants ; B2B Provider License Fees.         |
| "Aura Place"        | Environmental Sensors, AR, IoT (Software/Hardwar e) | Assistive Technology (AT) for in-home reablement, safety & autonomy. | General Consumer Electronics / AT (Largely non-medical) | Support at Home AT-HM Scheme .                   |
| "Aura Capsule"      | HBOT Pressure Vessel (Hardware)                     | Adjunctive wellness & longevity therapy (via pivoted B2B2C model).   | Medical Device (Class IIb/III)                          | Aura Access Co-operative ; Private Session Fees. |

Part 3: Corporate, Legal, and Tax

## Structure (The Three-Vehicle Model)

A single entity cannot pursue medical device R&D, government contracting, community-based hardware financing, and decentralised crypto-assets simultaneously. This would create an unmanageable tangle of legal liabilities and make the entity "un-investable." A "three-vehicle" structure is required to legally and financially firewall these distinct operations.

## 3.1 Vehicle 1: "Aura Health-Tech Pty Ltd" (The Core Commercial Entity)

- Structure: A standard Australian Proprietary Limited company.
- Purpose: This entity will be the "clean" commercial and legal face of the operation, designed to attract investment and hold key assets.
- Functions:
- Holds all Intellectual Property (IP) for the "Aura Clinical" and "Aura Place" software.
- Holds the TGA certifications (ARTG inclusion for the SaMD) and the QMS (ISO 13485).
- Applies for and receives all government grants (e.g., MRFF).
- Signs all B2B contracts with aged care providers (e.g., Bolton Clarke).
- Registers as a provider to receive payments from the AT-HM scheme.
- Engages all employees and key contractors.
- Rationale: This clean corporate structure is useful. An MRFF assessment panel or a venture capital firm like Brandon Capital will not sign a $2.5 million grant or investment cheque to a DAO or a newly-formed co-operative. They require a standard corporate entity for liability, governance, and IP management.

## 3.2 Vehicle 2: "Aura Access Co-operative Ltd" (The Access & Scaling Vehicle)

- Structure: A "Distributing Co-operative" registered in Queensland under the Co-operatives National Law (CNL).
- Purpose: To execute the (pivoted) B2B2C HBOT rollout. Its sole purpose is to "socialise the capital cost" of the "Aura Capsule" hardware and manage the member-access program.
- Legal Guidance (QLD Registration Process):
1. Formation Meeting: A minimum of five members is required to hold a formation meeting.
2. Draft Rules: The co-op could adopt rules compliant with the CNL. The most direct path is to adapt the QLD "Model rules for a distributing co-operative with share capital".
3. Draft Disclosure Statement: This is mandatory for a distributing co-op. It could be submitted to the Registrar at least 28 days before the formation meeting and could include estimated formation costs, member rights/liabilities, 1-year financial projections, and details of any required contracts. This serves as a mini-prospectus for founding members.
4. Lodge Application: The registration form, director details, two signed copies of the rules, and the approved disclosure statement are lodged with the QLD Office of Fair Trading.
- Tax Guidance (ATO):
- Distributing co-operatives are typically taxed as companies.
- The Key Mechanism: The co-operative can claim a tax deduction for "patronage rebates, bonuses or dividends on shares paid to members based on business transacted with the co-operative". This is the financial engine of the model. Surplus generated from member session fees is returned to members (to help pay down their micro-loans), and this rebate is deducted from the co-op's taxable income.
- Ideal Partner: Business Council of Co-operatives and Mutuals (BCCM) . They are the peak body and will provide useful guidance on setup, governance, and scaling.

## 3.3 Vehicle 3: "GAJRA Earth DAO" (The Philanthropic & Research Arm)

- Structure: A Decentralised Autonomous Organisation (DAO).
- Legal Guidance (ASIC & Corporations Act):
- IMPORTANT WARNING: As of November 2025, DAOs are not recognised as legal entities under Australian law.
- Liability: Without a legal "wrapper," the DAO is likely to be treated as a partnership. This exposes all members (token holders) to unlimited personal liability for the DAO's debts and actions.
- Solution: The DAO could have a "corporate wrapper," such as a "Pty Ltd" company or, more appropriately, a not-for-profit foundation or company limited by guarantee, to serve as its legal face and shield members from liability.
- Tax Guidance (ATO):
- The ATO is actively monitoring crypto-assets.
- "C-Hour" Token: The proposed "C-Hour" is a crypto-asset. Its creation and distribution create taxable events. Receiving it as a reward is likely an income tax event at its fair market value, and its subsequent sale or trade is a Capital Gains Tax (CGT) event .
- DAO Entity: The ATO's position on the DAO's tax status (partnership vs. company) is complex and depends on its specific structure and function.
- Regulatory Guidance (ASIC):
- ASIC is actively consulting on digital assets. The "C-Hour" token and the DAO's governance structure could easily be deemed a "financial product" or part of a "Managed Investment Scheme" under the Corporations Act. Operating such a scheme without an Australian Financial Services Licence (AFSL) is a serious breach.
- Strategic Recommendation: The DAO and "C-Hour" concepts are commercially toxic for the primary medical device mission. They introduce extreme legal, tax, and regulatory risk. They could be legally firewalled from Aura Health-Tech Pty Ltd. This vehicle should be positioned as a future, separate, philanthropic foundation . Its purpose can be to fund public-good research (using the "Aura" platform) and build the "Fractal Ark" as a global knowledge commons, but it cannot be entangled with the core commercial business.

## Table 3: Comparative Legal & Tax Structure Analysis

| Vehicle                  | Primary Purpose                             | Legal Status (QLD/Aus)                                       | Member Liability         | Tax Treatment (ATO)                    | Suitability for MRFF Grant   | Suitability for VC Investment   |
|--------------------------|---------------------------------------------|--------------------------------------------------------------|--------------------------|----------------------------------------|------------------------------|---------------------------------|
| Aura Health-Tech Pty Ltd | IP Holder, SaMD/AT Vendor, Gov't Contractor | Registered Company                                           | Limited (to shares)      | Standard Corporate Tax                 | Ideal                        | Ideal                           |
| Aura Access Co-op Ltd    | Hardware (HBOT) Access, Cost-Reducti on     | Registered Distributing Co-op                                | Limited (to shares)      | Corporate Tax (with rebate deductions) | Poor                         | Nil                             |
| GAJRA Earth DAO          | Philanthropic Research, "C-Hour" Economy    | Not a legal entity. Requires a "wrapper" (e.g., Foundation). | Unlimited (if unwrapped) | Highly complex. Tokens = CGT/Income.   | Nil                          | Nil                             |

## Part 4: Phased Commercialisation, Partnership, and Funding Roadmap

## 4.1 Phase 1: Validation (Years 1-3) - Focus: "Aura Clinical" & Dementia

- Primary Goal: Generate definitive clinical evidence for TGA approval of the "Aura Clinical" SaMD and secure foundational provider acceptance.
- Actions:
1. Establish Vehicle 1: Form "Aura Health-Tech Pty Ltd" to hold IP and prepare for grants.
2. Submit for HREC Approval: Immediately begin the Queensland HREC (Human Research Ethics Committee) submission process for the phased clinical trial (Feasibility, Pilot, RCT) outlined in the dementia care plan.
3. Apply for Grant Funding (Immediate Action):
- ■ Grant 1: MRFF 2025 Research Data Infrastructure Grant (GO7714) .
- ■ Rationale: This grant closes on 11 December 2025 . It offers grants of up to $2.5 million . The "Aura Clinical" project is a perfect fit, as its objective is to build novel data infrastructure (the digital twin) by linking disparate data types (biometric + narrative) to solve an important health problem (dementia).
- ■ Grant 2: MRFF 2025 Dementia, Ageing and Aged Care Mission (GO7589) .
- ■ Rationale: Stream 2 of this grant (now closed, but indicative of future rounds) directly funds "implementation research... of high-quality care for older Australians". This precisely describes the "Aura Clinical" trial.
- Ideal Partners (Approach Immediately):
- University of Queensland (UQ):
- ■ Target: Professor Jürgen Götz, Director, Clem Jones Centre for Ageing Dementia Research (CJCADR) .
- ■ Angle: The "Aura" platform is the data-gathering and implementation tool for their world-leading dementia and ultrasound research. CJCADR is actively focused on industry partnerships to move discoveries from the lab into the clinic.
- ■ Target: Professor Nadeeka Dissanayaka, Dementia & Neuro Mental Health Research Unit (DNMH) .
- ■ Angle: This group is an ideal research partner. Their work already focuses on developing and testing "psychotherapeutic programs to be delivered remotely, via telehealth and a smart voice assistant application" for dementia and Parkinson's. The "Aura Clinical" platform is a direct and powerful extension of their existing, funded research.
- Dementia Australia:
- ■ Target: Executive Director of Services, Advocacy and Research.
- ■ Angle: Seek a formal partnership. Dementia Australia has a track record of partnering on technology (e.g., the 'Ask Annie' app, 'Better Visit' app) and has existing close ties with UQ. This partnership provides clinical validation, access to consumers for co-design, and a powerful dissemination network.

## 4.2 Phase 2: Pilot Deployment (Years 2-4) - Focus: "Aura Place" & AT-HM

- Primary Goal: Secure the first government-funded revenue by launching the "Aura Place" platform into the "Support at Home" program.
- Actions:
1. Provider Registration: Use the data and legitimacy from Phase 1 to register "Aura Health-Tech Pty Ltd" as a Registered Provider under the Aged Care Act 2024 .
2. Product Launch: Commercially launch "Aura Place" as a non-medical, reablement-focused product, eligible for funding under the AT-HM scheme .
3. Provider Partnerships: Secure pilot sites with major providers to integrate the platform into their Support at Home service delivery.
- Ideal Partners (Provider):
- Bolton Clarke:
- ■ Target: Chief Information Officer and the Bolton Clarke Research Institute (BCRI) .
- ■ Angle: Bolton Clarke is the #1 strategic partner target. They have a stated, funded, and awarded corporate strategy for "Innovation through technology". Their focus includes "digital independence products," "interactive digital wallpaper for dementia care," and telehealth. They have an established Innovation Hub Framework for taking ideas "from innovation to commercialisation" and existing research partnerships (e.g., Flinders
- University). The "Aura Home" platform is a direct solution to their stated strategic needs.
- BlueCare (UnitingCare QLD):
- ■ Target: Head of Innovation / Digital Health.
- ■ Angle: As one of Queensland's largest and most trusted providers , BlueCare is the ideal local partner to transition the UQ-based (Phase 1) clinical trial into a real-world (Phase 2) pilot deployment within their residential and in-home care services.

## 4.3 Phase 3: Scaled Rollout (Years 4+) - Focus: "Aura Access" & Investment

- Primary Goal: Scale the validated, TGA-approved, and provider-partnered system nationally.
- Actions:
1. Launch "Aura Access Co-operative Ltd": Establish Vehicle 2 in formal partnership with the Business Council of Co-operatives and Mutuals (BCCM) and initial provider partners (Bolton Clarke, BlueCare).
2. Rollout HBOT Model: Execute the (pivoted) B2B2C co-op model. Use the co-op's microfinance structure to place the TGA-approved "Aura Capsules" into partner facilities, managed by their staff.
3. Seek Venture & Impact Funding: With TGA approval (SaMD), HREC-backed clinical data (from Phase 1), and initial B2B provider contracts (from Phase 2), "Aura Health-Tech Pty Ltd" will be positioned to raise a significant Series A funding round.
- Ideal Partners (Investment):
- Social Impact Investors: Social Ventures Australia (SVA) , which has a track record in aged-prevention tech like 'hayylo' , and HESTA , a superannuation fund with a dedicated impact investment trust focused on health and aged care.
- Health-Tech Venture Capital (VC): Brandon Capital (Australia's leading life-science and health-tech VC), Giant Leap Fund (an impact-focused VC), and OneVentures (a VC with a dedicated healthcare fund).

Table 4: Phased Funding & Partnership Roadmap (2025-2030)

| Phase               | Primary Goal   | Key Activities                                                                               | Target Grant / Funding                                                         | Key Partners                             |
|---------------------|----------------|----------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------|------------------------------------------|
| Phase 1 (Years 1-3) | Validation     | - Establish "Aura Health-Tech Pty Ltd" - Secure HREC Approval - File MRFF Grant Applications | MRFF 2025 Research Data Infrastructure (GO7714) MRFF Dementia Mission (GO7589) | UQ (CJCADR) UQ (DNMH) Dementia Australia |
| Phase 2 (Years 2-4) | Pilot Revenue  | - Register as Aged Care Provider - Launch "Aura                                              | Support at Home (AT-HM Scheme) Initial B2B License                             | Bolton Clarke (BCRI) BlueCare Aged Care  |

| Phase              | Primary Goal   | Key Activities                                                                                                  | Target Grant / Funding                                            | Key Partners                                     |
|--------------------|----------------|-----------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------|--------------------------------------------------|
|                    |                | Place" (AT product) - Secure TGA approval for "Aura Clinical" (SaMD)                                            | Fees                                                              | Quality & Safety Commission                      |
| Phase 3 (Years 4+) | National Scale | - Launch "Aura Access Co-op Ltd" - Execute pivoted HBOT rollout (B2B2C) - Raise Series A for "Aura Health-Tech" | Series A (VC & Impact Funds) Co-op Microfinance Patronage Revenue | BCCM Social Ventures Aust. Brandon Capital HESTA |

## Works cited

1. About the new rights-based Aged Care Act, https://www.health.gov.au/our-work/aged-care-act/about?language=en 2. Strengthened Quality Standards,

https://www.agedcarequality.gov.au/providers/quality-standards/strengthened-quality-standards 3. Aged Care Act 2024 - Federal Register of Legislation, https://www.legislation.gov.au/C2024A00104/latest/text 4. AGED CARE ACT 2024 (NO. 104, 2024) - SECT 187 - classic austlii,

https://classic.austlii.edu.au/au/legis/cth/num\_act/aca202457/s187.html 5. Aged Care Act 2024 (Cth) - BarNet Jade, https://jade.io/article/1109975 6. AGED CARE ACT 2024 (NO. 104, 2024) AustLII, https://classic.austlii.edu.au/au/legis/cth/num\_act/aca202457/ 7. AGED CARE ACT

2024 (NO. 104, 2024) - SECT 188 - AustLII, https://classic.austlii.edu.au/au/legis/cth/num\_act/aca202457/s188.html 8. Aged Care Rules Release 4b Public Release - Department of Health, Disability and Ageing,

https://www.health.gov.au/sites/default/files/2025-04/aged-care-rules-release-4b-public-releasesupporting-document.docx 9. Aged Care Rules 2025, https://www.health.gov.au/sites/default/files/2025-07/final-draft-of-the-new-aged-care-rules.pdf 10. Understanding regulation of software-based medical devices,

https://www.tga.gov.au/resources/guidance/understanding-regulation-software-based-medical-d evices 11. Australia Prepares Regulatory Shift for AI Medical Devices - Asia Actual, https://asiaactual.com/blog/australia-prepares-regulatory-shift-for-ai-medical-devices/ 12.

Software and AI medical device compliance | Therapeutic Goods Administration (TGA), https://www.tga.gov.au/how-we-regulate/manufacturing/manufacture-medical-device/manufactur e-specific-types-medical-devices/artificial-intelligence-ai-and-medical-device-software/softwareand-ai-medical-device-compliance 13. Australia's TGA Targets Digital Mental Health Apps: What AI Developers Must Know,

https://morulaa.com/news-australia-tga-regulation-digital-mental-health-apps/ 14. Ensuring healthy levels of AI regulation - the latest on the TGA and AI medical devices, https://www.tglaw.com.au/insights/ensuring-healthy-levels-of-ai-regulation---the-latest-on-the-tga -and-ai-medical-devices 15. TGA publishes consultation findings: AI and medical devices Technical update,

https://www.minterellison.com/articles/tga-publishes-findings-on-ai-and-medical-devices 16.

Medical device cyber security guidance for industry - Therapeutic Goods Administration (TGA), https://www.tga.gov.au/sites/default/files/medical-device-cyber-security-guidance-industry.pdf 17. About the Support at Home program - Department of Health, Disability and Ageing, https://www.health.gov.au/our-work/support-at-home/about?language=en 18. In-home aged care - IHACPA, https://www.ihacpa.gov.au/aged-care/home-aged-care 19. Support at Home program - Assistive Technology and Home Modifications (AT-HM) scheme, https://www.health.gov.au/sites/default/files/2025-06/support-at-home-program-assistive-technol ogy-and-home-modifications-at-hm-scheme\_0.pdf 20. Support at Home program manual - A guide for registered providers - Department of Health, Disability and Ageing, https://www.health.gov.au/sites/default/files/2025-10/support-at-home-program-manual-a-guide-f or-registered-providers.pdf 21. Assistive Technology and Home Modifications (AT-HM) scheme | Australian Government Department of Health, Disability and Ageing, https://www.health.gov.au/our-work/support-at-home/delivering-services-for-support-at-home/as sistive-technology-and-home-modifications-at-hm-scheme 22. Support at Home | Aged Care Quality and Safety Commission, https://www.agedcarequality.gov.au/older-people/support-home 23. Assistive Technology and Home Modifications (AT-HM) scheme guidelines - Department of Health, Disability and Ageing, https://www.health.gov.au/sites/default/files/2025-10/at-hm-scheme-guidelines\_0.pdf 24. Assistive Technology and Home Modifications list released | Aged Care Reforms - Wesley Mission Queensland, https://www.wmq.org.au/media/home-care/government-releases-the-assistive-technology-and-h ome-modifications-list 25. Assistive Technology and Home Modifications (AT-HM) scheme | My Aged Care, https://www.myagedcare.gov.au/aged-care-programs/assistive-technology-and-home-modificati ons-scheme 26. Support at Home provider training | Australian Government Department of Health, Disability and Ageing, https://www.health.gov.au/our-work/support-at-home/transitioning/provider-training 27. Transitioning to Support at Home - Department of Health, Disability and Ageing, https://www.health.gov.au/our-work/support-at-home/transitioning?language=en 28. How the Support at Home program works - Department of Health, Disability and Ageing, https://www.health.gov.au/our-work/support-at-home/about/how-the-support-at-home-program-w orks 29. Risk of fire during use of hyperbaric chambers | Therapeutic Goods Administration (TGA), https://www.tga.gov.au/safety/safety-monitoring-and-information/safety-alerts/risk-fire-during-use -hyperbaric-chambers 30. Queensland review of hyperbaric chamber legislation contained in the Health Regulation 1996, Public Benefit Test report - NCP, http://ncp.ncc.gov.au/docs/Qld%20review%20of%20the%20Health%20Regulation%201996%20 relating%20to%20Hyperbaric%20Chambers%2C%20PBT%20report.pdf 31. Medical device adverse event reports - statistics for 2013 - Therapeutic Goods Administration (TGA), https://www.tga.gov.au/sites/default/files/medical-device-statistics-2013.pdf 32. Corporate Law and the Legal Structuring of Decentralized Autonomous Organizations, https://www.dotlegal.com.au/legal-structuring-of-decentralized-autonomous-organizations/ 33. Current Grant Opportunity List - GrantConnect, https://www.grants.gov.au/Go/List?orderBy=Close%20Date%20%26%20Time%20-%20Ascendi ng&amp;GoId=&amp;Keyword=mrff&amp;KeywordTypeSearch=AllWord 34. Innovation | Bolton Clarke, https://www.boltonclarke.com.au/about-us/innovation/ 35. Top 9 Australian Investors Who Fund Healthcare Startups - Angel Match, https://angelmatch.io/publication/top-9-healthcare-investors-in-australia 36. Co-operatives

National Law (Queensland), https://www.legislation.qld.gov.au/view/whole/html/inforce/2025-08-05/act-2020-cnl 37. Co-operative - Business.gov.au, https://business.gov.au/planning/business-structures-and-types/business-structures/co-operativ e 38. Holding a formation meeting | Your rights, crime and the law - Queensland Government, https://www.qld.gov.au/law/laws-regulated-industries-and-accountability/queensland-laws-and-re gulations/associations-charities-and-non-for-profits/cooperatives/registering-a-cooperative/holda-formation-meeting 39. Model rules for distributing co-operatives with share capital Publications, https://www.publications.qld.gov.au/dataset/oft-registered-cooperative-forms/resource/223b5a94 -1d3c-43a6-9342-c39ae2b1c677 40. Creating the rules for your co-operative - Queensland Government, https://www.qld.gov.au/law/laws-regulated-industries-and-accountability/queensland-laws-and-re gulations/associations-charities-and-non-for-profits/cooperatives/registering-a-cooperative/creat e-the-rules-for-your-cooperative 41. Registering a co-operative | Your rights, crime and the law Queensland Government, https://www.qld.gov.au/law/laws-regulated-industries-and-accountability/queensland-laws-and-re gulations/associations-charities-and-non-for-profits/cooperatives/registering-a-cooperative 42. Co-operative Form 1 - Queensland Government publications, https://www.publications.qld.gov.au/dataset/1db2dee7-f096-4040-9d26-cb523d4084f3/resource/ 7f4f160a-76d9-4e5b-8f70-6407e6adb4e7/download/co-operatives-form-1.pdf 43. Co-operative forms | Your rights, crime and the law - Queensland Government, https://www.qld.gov.au/law/laws-regulated-industries-and-accountability/queensland-laws-and-re gulations/associations-charities-and-non-for-profits/cooperatives/cooperative-forms-and-fees 44. Co-operatives | 2025 - Not-for-profit Law, https://content.nfplaw.org.au/wp-content/uploads/2025/05/Co-operatives.pdf 45. KEY LEGAL ISSUES FOR CO-OPERATIVES IN AUSTRALIA, https://www.aph.gov.au/DocumentStore.ashx?id=3ae08c1a-91a5-439b-a869-22d9d31cfc78&amp;su bId=353387 46. Co-operative company franked and unfranked distributions - Australian Taxation Office, https://www.ato.gov.au/businesses-and-organisations/corporate-tax-measures-and-assurance/i mputation/in-detail/co-operative-company-franked-and-unfranked-distributions 47. Contact BCCM, https://bccm.coop/about/contact/ 48. BCCM: Home, https://bccm.coop/ 49. Business Council of Co-operatives and Mutuals - APO, https://apo.org.au/organisation/308953 50. What Is a DAO? Understanding Decentralised Autonomous Organisations and Their Legal Implications for Australian Businesses | Sprintlaw, https://sprintlaw.com.au/articles/what-is-a-dao-understanding-decentralised-autonomous-organi sations-and-their-legal-implications-for-australian-businesses/ 51. DAO Formation &amp; Governance | Blockchain Legal Services, https://blockchainaustralia.com.au/services/blockchain-consulting/blockchain-legal-consulting-se rvices/dao-formation-governance/ 52. Crypto asset investments - Australian Taxation Office, https://www.ato.gov.au/individuals-and-families/investments-and-assets/crypto-asset-investment s 53. Decentralised finance and wrapping crypto | Australian Taxation Office, https://www.ato.gov.au/individuals-and-families/investments-and-assets/crypto-asset-investment s/decentralised-finance-and-wrapping-crypto 54. DAO Taxes: Investor's Guide 2025 CoinLedger, https://coinledger.io/blog/dao-taxes 55. PwC - Submission in response to: Review of the Tax Treatment of Digital Assets and Transactions in Australia - | Board of Taxation, https://taxboard.gov.au/sites/taxboard.gov.au/files/2024-05/sub-26-pwc.pdf 56. CP 381 Updates

to INFO 225: Digital assets: Financial products and services | ASIC, https://www.asic.gov.au/regulatory-resources/find-a-document/consultations/cp-381-updates-to-i nfo-225-digital-assets-financial-products-and-services/ 57. ASIC updates INFO 225 and issues a class no-action letter for digital asset businesses, https://www.regulationtomorrow.com/au/asic-updates-info-225-and-issues-a-class-no-action-lett er-for-digital-asset-businesses/ 58. ASIC consults on update to digital asset regulatory guidance | Addisons | Sydney Law Firm, https://addisons.com/article/asic-consults-on-update-to-digital-asset-regulatory-guidance/ 59. Digital assets: Financial products and services - ASIC, https://www.asic.gov.au/regulatory-resources/digital-transformation/digital-assets-financial-produ cts-and-services/ 60. MRFF grant opportunities calendar - Department of Health, Disability and Ageing, https://www.health.gov.au/our-work/mrff/grant-opportunities-calendar?language=en 61. 2025 Research Data Infrastructure Grant Opportunity Guidelines - GrantConnect, https://www.grants.gov.au/Fo/DownloadDocument/27cf3795-c7bf-4a73-9b31-c123cbe56d95?do cType=Fo&amp;fileName=MRFF%202025%20Research%20Data%20Infrastructure%20Grant%20op portunity%20guidelines%20PDF.pdf&amp;location=s3Restricted 62. MRFF 2025 Research Data Infrastructure Grant Opportunity - Business.gov.au, https://business.gov.au/grants-and-programs/mrff-2025-research-data-infrastructure 63. MRFF 2025 Dementia, Ageing and Aged Care - Research support - The University of Queensland, https://research-support.uq.edu.au/resources-and-support/research-office/research-grants/fundi ng-schemes/medical-research-future-fund/mrff-2025-dementia-ageing-and-aged-care 64. MRFF - 2025 Dementia, Ageing and Aged Care Grant Opportunity (GO7589) - NHMRC, https://www.nhmrc.gov.au/funding/find-funding/mrff-2025-dementia-ageing-and-aged-care-grantopportunity-go7589 65. Clem Jones Centre for Ageing Dementia Research (CJCADR) Queensland Brain Institute, https://qbi.uq.edu.au/centres/CJCADR 66. Queensland Brain Institute Awarded $1M for Research on Alzheimer's Disease, Dementia, https://www.fusfoundation.org/posts/queensland-brain-institute-awarded-1m-for-research-on-alz heimer-s-disease-dementia/ 67. Ultrasound innovation gets a boost - Queensland Brain Institute, https://qbi.uq.edu.au/article/2025/10/ultrasound-innovation-gets-boost 68. Dementia Centre for Clinical Research - University of Queensland, https://clinical-research.centre.uq.edu.au/research/research-areas/dementia 69. Neuro Mental Health - Dissanayaka Group - UQ Centre for Clinical Research - The University of Queensland, https://clinical-research.centre.uq.edu.au/dissanayaka-group 70. Dementia Consumer Resource Launch - Country to Coast QLD, https://c2coast.org.au/dementia-consumer-resource-launch/ 71. Our corporate partners | Dementia Australia, https://www.dementia.org.au/about-us/our-corporate-partners 72. Dementia Friendly University Initiative - Current staff, https://staff.uq.edu.au/information-and-services/human-resources/diversity-and-inclusion/age-an d-dementia-inclusion/dementia-friendly-university-initiative 73. Designing an Innovation Framework for Aged Care - The Strategy Group, https://www.thestrategygroup.com.au/case-studies/designing-an-innovation-framework-for-aged -care 74. New partnership to deliver evidence-based nursing in aged care | Bolton Clarke, https://www.boltonclarke.com.au/news-resources/corporate-news/new-partnership-to-deliver-evi dence-based-nursing-in-aged-care/ 75. Creating partnership in iSupport program to optimise carers' impact on dementia care, https://isupportcarers.com.au/wp-content/uploads/2022/03/MRFF-project-Overview\_Lily-Xiao.pd f 76. Who we are | BlueCare, https://www.bluecare.org.au/about-us/who-we-are 77. Impact investing - Social Ventures Australia, https://www.socialventures.org.au/about/impact-investing/

78. IMPACT INVESTING - Allens, https://www.allens.com.au/globalassets/pdfs/sectors-services/funds/impact-investing-thought-le adership-brochure.pdf 79. Top 50 Health Care VC (Venture Capital) Funds in Australia in September 2025, https://shizune.co/investors/health-care-vc-funds-australia 80. List of Early Stage Venture Capital Limited Partnerships | business.gov.au,

https://business.gov.au/grants-and-programs/early-stage-venture-capital-limited-partnerships/list -of-early-stage-venture-capital-limited-partnerships
