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NANC Not Followed

FCC's 988 Choice for Suicide Prevention Won't End Number Debate

Faced with divisions whether to repurpose 611 for a national three-digit suicide hotline or add that to 211 (see 1812110033), the FCC is recommending to Congress 988 be used instead. That route may not become a compromise solution all stakeholders rally behind, interviews show.

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The Wireline Bureau and Office of Economics and Analytics in a 988 recommendation released Thursday pointed to the threat of caller confusion and delays. The agency said the next step is an NPRM for designating 988.

United Way Senior Vice President Steve Taylor said the 988 recommendation, which didn't follow the North American Numbering Council (NANC) suggestion to the FCC regarding expanded use of 211 (see 1905080020), was a surprise. He said UW hasn't decided how it would respond, but that it's unlikely advocates for 211, like UW, or 611 backers would change their minds even if 988 is supposed to be a compromise. Taylor said a shortcoming of the 988 recommendation is FCC cost-benefit analysis doesn't include all infrastructure costs that might have to be spent for the number, and the report doesn't indicate how that might be paid for. He said an advantage of 211, used for community service referrals, is infrastructure needs are largely taken care of.

FCC estimates include $92.5 million for switching translation updates by service providers and up to $300 million for replacing some legacy switches to accommodate the 988 code and $250 million for a two-year national multimedia awareness campaign. After the first two years, $50 million annually could be needed for additional funding for crisis center upgrades or expansions to handle anticipated increased call volume.

The recommendation said advantages include that it's not assigned as a geographic area, and is easier than repurposing an existing area code. An existing N11 code would have to sit unused for a period before repurposing, and using 988 means a shorter implementation timeline, it said. It said any consumer education campaign also would be simpler, focused strictly on the new hotline, which also makes for a quicker rollout.

Giving suicide prevention its own number, instead of a hand-me-down or making it dual-purpose with another use, is also symbolically powerful, said American Association of Suicidology board member Bart Andrews. While 988 is the best-possible decision, Andrews added that the plan isn't likely to end advocacy by other parties for expanded 211 usage or another alternative. Congress is likely to be very receptive to the agency recommendation, he said.

Rep. Chris Stewart, R-Utah, who has pushed for 611 (see 1812110033), tweeted he was "thrilled" the FCC determined a three-digit code "is feasible for a national suicide hotline crisis center. This is another important step towards saving lives!" Stewart's office didn't comment further.

The American Counseling Association emailed it "strongly supports this effort." With "the increase in people attempting and dying by suicide, it is critical that every effort be made to facilitate the ability of people in crisis to access appropriate help," it said.

While 211 is used for crisis calling in parts of the U.S. and service providers are well-versed in routing 211 calls, 211 "is not appropriate," the agency wrote. It said there needs to be a single-purpose number and the record showed broad support for either a repurposed N11 number or a new, non-N11 number, with only UW and blended 211 crisis centers backing the NANC recommendation. The agency pointed to Substance Abuse and Mental Health Services Administration experience with a dual purpose hotline that resulted in confusion.

The report said repurposing an N11 number poses separate challenges, including the possibility of either number having to sit idle for years while an education effort is underway. It said that while the commission isn't concerned with wireline and wireless carrier use of 611 for customer service purposes, the 300 million calls made annually via 611 for that purpose means using it for suicide prevention instead would result in a deluge of misdirected callers.

While 911 is "the gold standard for emergency response," it's not well suited for suicide prevention counseling or handling calls that involve conversations with trained mental health professionals instead of first-responder dispatching, the regulator said.