Expanded 211 Best Option for National Suicide Prevention Hotline, NANC Says
If there's to be a national three-digit suicide hotline number, expanding use of 211 -- already employed for community service referrals including crisis- and mental health-related calls in parts of the U.S. -- is the best route, with a 211 administrator to oversee that work, said the FCC North American Number Council. NANC on Wednesday unanimously adopted a report from its Numbering Administration Oversight Working Group.
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National number portability got no such agreement. The NNP Issues Working Group didn't reach consensus on either of the two possible models: a non-geographic local routing number or an IP LRN. Somos Vice President-Industry Relations and Public Policy Mary Retka said there were significant discussions on areas such as impacts of interconnection to compensation, tariffs and access charges, and the conclusion was those areas need more study.
Plusses for 211 include its interactive voice response (IVR) system capabilities can be used to route veteran and service member calls on a priority basis to the vets' crisis line, and 211 services cover 94 percent of the U.S. population so service providers know how to route calls to it, said the report. It said about 25 percent of the national suicide prevention line call centers are also 211 call centers. It said Veterans Affairs Department and Substance Abuse and Mental Health Services Administration (SAMHSA) projections point to crisis and suicide call volumes beyond what expanded 911 could reasonably handle, while IVRs on 911 calls aren't practicable. It said costs to transition existing users to alternatives and disruption of existing services preclude expanding any other N11 dialing code.
The 211 recommendation "warrants serious consideration" yet raises concerns about confusion and conflict that could come with use of a dual-purpose number, said Richard McKeon, SAMHSA suicide prevention branch chief. Also concerning is not all 211 centers have crisis capacity, and there needs to be thought about structural issues such as ensuring a system of backup centers when a local center can't answer a call quickly, he said.
If not 211, the next best option is the non-N11 code 988, though it likely couldn't be deployed ubiquitously on all networks, NANC said. It said under the 988 option, mandatory 10-digital dialing might have to be used in area codes where 988 is assigned as a central office code.
NANC said no N11 code should be repurposed for a crisis hotline. The group said the FCC should consider periodically reviewing all N11 uses, since technology may make some of the codes' current designations moot, opening the door to their future repurposing. If there's not 211 expansion and an N11 code must be repurposed, 511 is the best because it's not ubiquitously deployed and could be the most expeditiously repurposed with least user impact, it said.
NANC recommended existing 800-SUICIDE and 800-273-TALK continue to operate concurrently as long as they have significant call volume.
The council report said repurposing an existing N11 code or creating a non-N11 three-digit code -- with translation updates to every originating switch in the U.S. -- would cost $92.5 million. It said expanding 211 would cost $5.6 million. Estimates are service provider costs for network translations and upgrades, and exclude national suicide hotline platform provider costs for deployment, or a marketing and awareness campaign. It said use of a non-N11 code such as 988 would have similar network costs to repurposing an N11.
"There's no cheap and easy solution that doesn't upset somebody," said former FCC Chief Technology Officer Henning Schulzrinne, now a Columbia University computer science professor. He said many carriers don't use 611 and transitioning should have been given more serious consideration. Carriers sometimes use 611 for customer service and repairs-related calls.
In N11 call volume, 611 accounts for almost half, 911 for close to 30 percent, and 211 gets about 3 percent of calls, said Bob McCausland, West Telecom Services vice president-regulatory and government affairs.
NANC Chairman Travis Kavulla said the FCC suicide hotline report to Congress, due in August and to be informed by SAMHSA, the VA and NANC, presumably won't be a binding determination on what to do but will give guidance to legislators. He said NANC would send its NNP report to the FCC to see if commissioners wanted to follow "with any dispositive policy calls."
SIP Forum Chairman Rich Shockey said carriers are under pressure to implement call authentication technology, a potential NNP mandate and potentially IP interconnection requirements. Major carriers might be able to absorb the requirements, but for rural carriers and some CLECs, "this may well be a bridge too far," he said. Shockey urged NANC eschew both options and look more closely at cost issues. Shockey was the lone vote against the NNP report and said he would provide a minority dissent report.