On April 26, the FCC released a Second Notice of Proposed Rulemaking (Notice) in Docket 18-336, proposing improvements for wireless call routing to the 988 Suicide & Crisis Lifeline that would connect callers in crisis to behavioral health resources in their current state or county. Calls to 988 are today routed based on the calling phone’s area code and exchange, which presents obvious problems to callers whose area code does not correspond to their current location. Under the Commission’s proposed solution, georouting would be used to ensure that a person in crisis, dialing the suicide hotline, would receive help from a nearby location.
Here is how calls to the 988 hotline are currently routed:
Under current Commission rules, calls to 988 must first be routed to the existing toll free ten-digit access number for the 988 Lifeline (1-800-273-8255). When the Commission established 988, it found that such routing would be the most efficient means to enable 988 callers to reach the existing national suicide prevention hotline, and explained that routing to the 988 Lifeline’s toll free number provided “considerable benefits” both for covered providers and the 988 Lifeline itself, which would enable faster implementation, lower costs to maintain 988 routing, and better service. Calls to the 988 Lifeline’s toll-free access number are terminated to a single aggregation point, specifically, an interactive voice response (IVR) where callers are provided with a menu of connection options. Veterans, service members, and their families may connect to the Veterans Crisis Line operated by the Department of Veterans Affairs by pressing “1.” Callers may also reach a Spanish language line by pressing “2” and specialized LGBTQI+ services by pressing “3.” All other calls are routed to one of over 200 regional crisis centers based on the area code and exchange of the caller’s telephone number supplied by the originating service provider. In the event that a center is unable to answer, the call is routed to the Lifeline’s national backup network. (Notice at para. 9).
This methodology clearly was designed for a wireline world. Today it is totally inadequate for people who take their cellphones everywhere and may suffer a mental crisis far away from home. Therefore, the Commission believes that georouting is the only real solution to the growing issue of connecting wireless callers to a local help center.
This past summer, the Substance Abuse and Mental Health Services Administration (SAMHSA), as well as the administrator of the 988 Lifeline, Vibrant Emotional Health (Vibrant or Lifeline Administrator), successfully completed a proof-of-concept trial of a potential solution for routing wireless calls to geographically appropriate crisis centers. The proof of concept was conducted using calls in a testing environment, and successfully routed calls from wireless handsets to the nearest crisis call center based on the location of the cell tower that originates the call. In the Notice, the Commission requests carriers to work with SAMHSA to perform further tests. In addition, the agency wants to hear about other possible methods of georouting.
Each commenter must answer:
- How the proposed solution identifies the caller’s location and correlates that location with a geographically appropriate crisis call center?
- What are the technical limits of the method?
- What network infrastructure and system changes or upgrades may be required at each step of the call path for wireless carriers to successfully implement the proposed georouting solution?
- What are the costs and benefits of the solution?
- How long would it take to implement the georouting?
Comments on the Notice are due 30 days after it appears in the Federal Register. Reply comments are due 30 days later.