Editing PHKG Business Opportunities (section)

=== Challenges ===

* '''ROI doesn't survive RCT scrutiny:''' The sell to employers is talent/retention/risk-management, not direct healthcare savings — softer, slower sale.
* '''BHT incumbents own the employer relationship:''' Going around them is hard; going through them requires partnership terms that compress margins.
* '''GDPR Article 9 + employee consent:''' Near-blocking constraint on data architecture. Employer can't be data controller for employee health data.
* '''Participation rates 20-40%:''' Unit economics ~3x worse than wiki's original example.
* '''Not a core competency:''' Different sales motion (HR director, not hospital CIO). Distracts from core EHDS play.
* '''Competitive density:''' Neko's likely B2B roadmap, Nightingale's existing employer business, BHT providers, insurer-bundled offerings all crowd the space.