The FCC’s Wireline Competition Bureau and Office of Economics and Analysis has recommended that the three-digit dialing code “988” be allocated for a national suicide prevention and mental health hotline, and FCC Chairman Ajit Pai responded today by saying that he plans to act on the recommendation.
In a report delivered to the congressional committees with jurisdiction over the FCC, health, and veterans issues, pursuant to National Suicide Hotline Improvement Act of 2018, the bureau and office said that the “988” dialing code could be implemented as a national suicide prevention hotline more quickly than any of the “N11” dialing codes.
The National Suicide Hotline Improvement Act required the FCC, in coordination with the Health and Human Services and Veterans Affairs departments, to study the feasibility of designating an N11 or other three-digit dialing code for a national suicide prevention and mental health crisis hotline system (TR Daily, Aug. 14, 2018).
In a statement today, Chairman Pai said, “There is a suicide epidemic in this country, and it is disproportionately affecting at-risk populations, including our Veterans and LGBTQ youth. Crisis call centers have been shown to save lives. This report recommends using a three-digit number to make it easier to access the critical suicide prevention and mental health services these call centers provide. I intend to move forward on this recommendation. In the meantime, my heart goes out to anyone facing a crisis. I hope they will contact 1-800-273-TALK for support today.”
In a press release, the FCC said that “Chairman Pai is committed to launching a rulemaking proceeding in which the Commission would consider designating a 3-digit number—specifically, 988—for a national suicide prevention and mental health crisis hotline.”
The FCC staff report notes that the Department of Health and Human Services’ Substance Abuse and Mental Health Services Administration has said that an easy-to-remember number “would lead to more people who are in need of help being able to access it” and that “the combination of the N11 number and the message that mental health crises and suicide prevention are of equivalent importance to medical emergencies would, over time, bring needed parity and could result in additional attention and resources to improve typical local psychiatric crisis services throughout the nation.”
The FCC staff had asked the North American Numbering Council to report on several possibilities: “expanding an existing N11 code, repurposing an existing N11 code, and using a new non-N11 code.” NANC recognized that expanding an existing N11 code, such as 211, would require “callers in crisis to navigate an interactive voice response system, and the potential training deficit of individuals answering 211 calls,” the FCC staff report says.
In addition, existing codes that are widely deployed would require extensive consumer re-education if they were to be repurposed for a national suicide prevention hotline.
“Ultimately, the NANC recommended expanding the 211 code beyond providing community services to include crisis and suicide prevention services, stating that is technically feasible and would be the most expedient and beneficial in providing easy access to suicide prevention and mental health crisis support services. However, the NANC also recommended that, if a single-purpose code is preferred, a new 3-digit dialing code—preferably 988—could be deployed for the use of a national suicide prevention and mental health crisis hotline. The NANC did not recommend repurposing an existing N11 code at this time; however, it noted that if one must be repurposed, the 511 code would be the best option in part because there are many alternatives to obtain traveler information, and the 511 code would be the most expeditiously repurposed with the least impact on users. Finally, the NANC recommended that the Commission conduct a Notice of Proposed Rulemaking proceeding before adopting any final order designating a 3-digit dialing code,” the FCC staff report says.
The FCC also sought public comment last year. “Although there is widespread agreement in the record that the FCC should designate a 3-digit dialing code for this purpose, there is no consensus among commenters on which code should be designated,” the staff report says.
“Some commenters further argue for the need for specialized hotline services for higher-risk populations, including LGBTQ youth and Veterans. Such specialized services could include establishing an interactive voice response system ‘to a group that has the resources and expertise to best serve [LGBTQ youth]’ and ‘for specialty partners across all at-risk groups to assist SAMHSA in conducting further trainings to increase the ability for existing counselors to best service callers,’” the report notes.
The report “conclude[s] that 211 is not appropriate for a nationwide suicide prevention hotline because it could create confusion and additional delays to callers in crisis.”
Repurposing “511” for a suicide hotline “poses several challenges. Most importantly, it appears that states and localities use 511 to enable drivers to receive information on road conditions during emergencies and information pertaining to AMBER and other public safety-related alerts. For this reason alone, we do not believe that 511 should be repurposed. Moreover, while 511 is used less than other N11 codes, the data provided by the NANC indicate that an estimated 13.6 million calls are made to 511 annually. Accordingly, as with repurposing of any N11 code, current use of 511 would have to be discontinued, the code would have to be aged for an extended period of time based on this usage, and the public would need to be re-educated as to the new use. This process risks creating public confusion and delaying the implementation of a 3-digit dialing code for a national suicide prevention and mental health crisis hotline system,” the report says.
“In considering the feasibility of designating 611, we make clear that our primary concern is not the interests of or burden on carriers that currently use this code. Rather, our focus is on the effectiveness of repurposing a code with such heavy existing usage for a national suicide prevention and mental health crisis hotline. In particular, while 611 has not been officially designated by the FCC, data indicate that this code receives nearly 300 million calls annually. We are therefore concerned that repurposing an N11 code with such high usage would result in a crisis hotline being inundated with misdirected callers seeking other information, causing confusion and delay, and potentially lost lives if a caller in need cannot speak with a counselor quickly. … Based on experience with transitioning to new numbers, such as the transition from 800-SUICIDE to 800-273-TALK, the significant call volumes of 611 suggest that it would need to lie fallow for many years longer than one of the less-used N11 codes, such as 511,” the report says.
Other N11 codes, such as 311 (non-emergency and other government services), 411 (directory assistance), 711 (disability access), and 811 (call-before-you-dig services), present problems of relocating existing uses or educating the public about the change, the report says.
The report rejects expanding or repurposing 911 for a national suicide hotline. “[C]alls to 911 average 2 minutes or less, and 911 call-takers focus on identifying the nature of the emergency and the caller’s location to enable prompt dispatch of appropriate emergency response. Thus, the 911 system is not well-suited to provide suicide prevention counseling or to respond to calls that can be handled through conversation with a trained mental health professional rather than dispatching first responders. In addition, the suicide call-volume projections from SAMHSA and the VA indicate that directing these calls to 911 would increase call volumes above levels that the 911 system can reasonably be expected to accommodate,” the report says.
The number recommended, 988, “has technical advantages. First of all, it is not currently assigned as a geographic area code and therefore does not suffer the same problems surrounding repurposing an existing area code. In addition, in order for a switch to detect a new, non-N11 three-digit code, it helps if the code is not comprised of the leading digits (often called the ‘prefix’) of a local number. In this regard, 988 has fewer corresponding central office code assignments across the U.S. than some other codes the NANC considered,” the report says.
NANC did say that “[s]ome wireline switches may be unable to support any new 3-digit dialing code that is not an N11 code,” the staff report says. However, the report adds, “it seems that the current technical and operational concerns related to the 988 code could be more easily and quickly addressed and resolved than any re-education efforts related to repurposing a N11 code. Although we believe 988 is the fastest path to implementing a 3-digit code, Commission staff estimates that a relatively small percentage of legacy switches cannot accommodate the 988 code. As telephone companies continue to upgrade their legacy networks, we expect these legacy switches will be replaced, ultimately making the use of 988 as a designated suicide prevention and mental health crisis hotline ubiquitous.”
As for its cost-benefit analysis of the issue, the report says that based on the cost of implementation of the three-digit dialing code and the Department of Transportation’s calculation of the Value of a Statistical Life (VSL) as $9.6 million, the suicide risk would have to be reduced by 60 statistical lives for the benefits to exceed the costs.
“Based on our consultation with the SAMHSA and the VA, we expect that the life-saving benefits of a simple, easy-to-remember 3-digit dialing code such as 988 will exceed the costs of implementation. Crisis call centers save lives. The most recent SAMHSA-funded study found that for callers at imminent risk of committing suicide, counselors sent emergency responders with the caller’s cooperation in 19% of the cases; in another 55% of cases, counselors were able to help callers avoid suicide without police or ambulance services. Moreover, empirical studies of suicidal callers have found reductions as large as 25% in callers wanting to self-harm after speaking with hotline counselors,” the report says.
The staff report was submitted yesterday to the Senate Commerce, Science, and Transportation Committee, the Senate Health, Education, Labor and Pensions Committee, the Senate Veterans’ Affairs Committee, the House Energy and Commerce Committee, and the House Veterans’ Affairs Committee. It was released publicly today. —Lynn Stanton, [email protected]
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