CAREFUL DECISIONS ON GEOROUTING FOR SUICIDE HOTLINE

In some of the darkest human moments – when individuals contemplate taking their own lives – confidential and free help is available from caring and understanding crisis personnel. Several years ago, Congress and the Federal Communications Commission (FCC) established the short-code 9-8-8 to simplify and accelerate the means to reach this support. And further improvements are coming as the entire suicide prevention lifeline eco-system is adopting technology enhancements to transmit calls and texts to more localized crisis centers, all without jeopardizing anonymity. This move to better-targeted “georouting,” which is most relevant for wireless mobility users, can be an undeniable success story – but only if regulators are careful before layering new government mandates or disrupting the current 988 Lifeline system. 

Numerous experts involved in 988 have made clear that familiarity with community and local factors of individuals in need can aid in immediate response care. It also can be vital in providing longer-term assistance and preventing reoccurring episodes. In fact, the pertinent FCC proceeding received ample comments that more precise georouting would be invaluable. It’s why the industry partners, the Lifeline Administrator (Vibrant), the Substance Abuse and Mental Health Services Administration (SAMHSA) of the Department of Health and Human Services, and others have been rapidly and voluntarily working on ways to increase the precision of such call routing.

Just this week, two nationwide wireless providers, T-Mobile and Verizon (with AT&T not far behind), have successfully activated a 988 wireless call georouting system. In other words, the system testing of 2023 has moved to a fully live, implemented, and operationally-sound 988 structure that delivers an individual’s call to the respective local crisis center.

For the FCC, these developments should be welcome news. After defining an appropriate policy objective, it gets exactly what it sought without having to impose new regulations. Embracing this win-win opportunity will increase the likelihood of reducing the number of suicides and the devasting impact on affected family and friends. It also prevents legal challenges questioning FCC legal authority to impose mandates that would result in the same outcome or worse. Arguably, the Commission’s reliance on existing statutory provisions, which at best are thinly related or over encompassing, is troubling and inappropriate, especially given the U.S. Supreme Court’s recent paring of independent agency reach.

To the extent that the FCC moves ahead notwithstanding, which I humbly would suggest is unnecessary, it should do so without interfering with or jeopardizing the existing 988 system and the work that’s handled over 10 million connections. Such a transition should facilitate a seamless integration that respects current systems features and doesn’t require a retrofit and redesign of the 988 architecture. Preventing wasted time and expense should be a key priority to allow crisis centers to focus on their good work of helping callers. Likewise, the agency should be mindful that improving georouting doesn’t result in more network exposure points for potential failure or outages. Anyone who has focused on computer operations and security knows the more complexity and touchpoints, the more chance for network failure.

Take for instance, the current system’s ability to conduct an initial screen for callers who are veterans, Spanish speaking, and/or LGBTQI+ individuals. Today, those calls – which represent approximately 25 percent of total volume – are handed to crisis counselors with specialized experience and training. Any georouting solution that does not propose ways to maintain or replicate this critical technological protocol should raise concern. That is, considering an option for georouting that ignores continuing this quality of care should serve as a red flag that very well could lead to an increase in suicide risk.

Further, the current 988 Lifeline system avoids many of the issues relevant in Next Generation 911 (NG911) system design and adoption. Policymakers are well aware that the migration to a unform NG911 is occurring haphazardly and on a very slow timeline. More importantly, the system serves different functions than 988 and callers have completely different expectations. Identifying individuals’ locations and communicating with law enforcement personnel – hallmark attributes of NG911— can undermine the willingness of those considering suicide to seek assistance. Any georouting solution endorsed by the FCC should want to keep these two opposing worlds separate for the continuity of suicide prevention.           

Mandates by the FCC to move to greater georouting without direction from Congress would be disturbing. As a former FCC Commissioner, I am hard pressed to imagine why the agency would want to require that which is already being accomplished. However, if it does, systemic changes to the successful 988 system shouldn’t be made lightly or without a recognition of current system’s intentional design and features. Tread carefully.