Better 988 Routing Seen as Doable, but Geolocation 'Contentious'

National Alliance on Mental Illness (NAMI) Chief Advocacy Officer Hannah Wesolowski said the organization hopes for regulatory action to improve routing sometime this year by the FCC, since the issue is clearly on the agency's radar. She said calls and texts to 988 now are routed based on the caller's area code. That becomes a problem when a person lives in one region of the country but has a phone number from a different region -- an increasingly common occurrence, she said. The caller will still reach trained crisis counselors, but those counselors will struggle to link that caller to community resources such as local mental health providers, she said.

A related and thornier issue is 988 calls and texts coming with data letting the call center know the address or specific location where the call is coming from, Wesolowski said. Some 988 callers need immediate intervention, such as crisis responders, but there also are concerns about people being hospitalized or jailed, she said.

LIfeline's "active rescue" policy -- meaning actions taken to secure the safety of people at imminent risk, even without consent of those people -- "is a bit contentious" and a source of debate, said David Jobes, Catholic University psychology professor and American Foundation for Suicide Prevention board member. Of particular concern is that calls seeking a safety check "can sometimes go sideways" if police are involved, he said. He said when 988 first went live last year, criticisms about police response to mental health crises were "sort of shocking" to Lifeline backers, he said.

Such improved routing of 988 calls and texts to the appropriate call center is inevitable, but geolocating of callers for emergency response is more doubtful because of the lack of consensus, said April Heinze, National Emergency Number Association 911 and public safety answering point operations director. She said actions to better route calls would require technology implementation by carriers different from what was needed for routing 988 calls to Lifeline. She said even if there were regulatory movement by the FCC, it would still take "some time" for carriers to make that improved routing happen.

Today if someone calls 988 and appears to be at imminent risk of self-harm, Lifeline will contact 911, Heinze said. The problem 911 and first responders face is that if the caller hasn't provided a location, there's a significant delay before response can be dispatched because of the process of "exigent circumstances lookups," she said. Those lookups can require a subpoena, and can take from 15 minutes to 90 minutes before there's information that can be used to dispatch, she said. Improved routing of 988 calls would shave off some of that time, she said.

Heinze said if the FCC were to require the same standards for technical delivery of 988 calls as it does 911, NENA's L3 standard would allow suppression of location when the call is made to 988, though the call could still be routed to the closest PSAP in cases of imminent risk, and dispatch at that PSAP would have access to that location information.

Call routing and geolocation are related issues, "but involve different technical, legal, privacy, and cost considerations," an FCC spokesperson emailed. She said the agency is analyzing information gathered from a May forum on 988 geolocation, "including whether potential routing improvements could help callers to 988 connect to the regional call centers where they are located without sharing geolocation information."

The 988 outage reporting NPRM on the agency's January agenda (see 2301040056) makes sense because following similar reporting requirements for 911 means not having to create all new processes, Heinze said. USTelecom and Lifeline administrator Vibrant Emotional Health didn't comment.