I believe the NetBSD ath source, and in fact most of the wireless support, was originally imported from FreeBSD. It appears that last changes in NetBSD were done about 3 years ago. A quick check of FreeBSD shows they've made changes as recently as three months ago. In fact the ath driver in FreeBSD 10.0 claims to support *all* Atheros devices except those based on the AR5005VL chipset. Wish I was capable of importing the FreeBSD wireless code back into NetBSD as it sure would bring the system up to date and make it much more capable of supporting a lot of the newer wireless devices now on the market.
All the cards that I've found and tried to use that didn't work with NetBSD would have worked with FreeBSD based on my reading of the Version and Device codes.