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April FNPRM Vote

Adequacy of Lifeline's Text-to-988 Resources Unclear

Five of the National Suicide Prevention Lifeline's 180 centers nationwide already have the technology and staff training to handle text-to-988 and chat messages, and it's not clear whether they will need more if the FCC mandates that providers support texting 988, we're told. Kim Williams, CEO of Vibrant Emotional Health, which administers Lifeline, said the Department of Health and Human Services' Substance Abuse and Mental Health Services Administration is working on a report that would include recommendations. SAMHSA said it's partnering with the FCC and carriers on the approach to implementing three-digit functionality for Lifeline. It said the ability of call centers to accommodate text-based utilization "has been -- and will continue to be -- a focus of the hotline’s operations." The FCC will vote at its April meeting on a Further NPRM on text-to-988 requirements and a possible July 16, 2022, implementation deadline (see 2103310054).

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Becky Stoll, American Association of Suicidology crisis center division chair, said the key issue isn't so much the number of centers with such capabilities but adequate funding for the staffing to provide the service.

Williams said Vibrant is talking with stakeholders, including states, to determine what will be needed for infrastructure planning and resources for launching 988 in 2022, including text capabilities. "Universal and convenient access" to 988 is important, and texting's omnipresence with some population groups such as youths means it likely will be the first way they might contact the three-digit suicide prevention system, she said.

The five Lifeline designated texting centers all use the same integrated platform for handling text and chat traffic now, Williams said. Lifeline centers typically also are community call centers for a variety of other crisis lines, and many of the other Lifeline centers have the capability to handle texts for those other lines, she said.

Attention should also be on other modes of reaching people in crisis, such as via social media, Williams said: "We want to make it as easy as possible for those in distress ... to get access."

The wireless industry generally accepts requiring that carriers enable texting to the 988 nationwide suicide hotlines, as long as it's implemented consistently with existing SMS capabilities and Lifeline has demonstrated the appropriate readiness to receive and respond to text-to-988, CTIA said last year. USTelecom didn't comment.

"Given the pervasiveness of text messaging, it is essential to explore making it possible to reach the Lifeline by text through the same short, easy-to-remember code by which Americans will be able to call the Lifeline," the FCC said in its FNPRM. It said the agency held off on a texting mandate in its 988 order last year (see 2007160030) because Lifeline wasn't capable then of receiving or responding to texts, but its ability now to respond "significantly strengthens the case for imposing a text-to-988 mandate on providers."

The agency also asks for feedback on such items as the definition of text messages that covered providers may be required to transmit to 988, and whether that should include "next-generation forms" such as multimedia message service, rich communications services and real-time text. The FCC proposes in the FNPRM to require that covered text providers route covered 988 messages to the Lifeline’s current 10-digit number, 800-273-8255. It also asks about another possibility: requiring that text providers route messages directly to a public safety answering point such as a Lifeline local crisis center or Veterans Crisis Line center. However, the FCC said, the latter approach would likely be quite a bit more expensive.

Cooperative Telephone in a 988 waiver request last week in docket 18-336 asked for one more year, until July 16, 2023, to transition to 10-digit dialing. It said it will offer direct 988 access by the 2022 deadline, but the waiver would give it "much-needed additional time" for customer education.