Section 5 of the National Suicide Hotline Designation Act requires the Federal Communications Commission (FCC) to submit a report to the appropriate Congressional committees “that examines the feasibility and cost of including an automatic dispatchable location that would be conveyed with a 9–8–8 call, regardless of the technological platform used and including with calls from multi-line telephone systems.” (See the full Public Notice here.)

As the administrator of the National Suicide Prevention Lifeline and other crisis lines, including the Disaster Distress Helpline, NYC Well, and NFL Life Line, Vibrant Emotional Health encourages crisis centers, stakeholders, and advocates to submit comments regarding this important issue.

Regarding Vibrant Emotional Health’s position and recommendation regarding geolocation and 988:

A brief summary of our recommendation can be found in our “988 Serviceable Populations and Contact Volume Projections” Report, available at this link.

Talking points related to Vibrant’s position on geolocation can be found below.

Geolocation Talking Points

Location information is identified as a key component for best practices and guidelines for behavioral health crisis care by the Substance Abuse and Mental Health Administration (SAMHSA). (https://www.samhsa.gov/sites/default/files/national-guidelines-for-behavioral-health-crisis-care-02242020.pdf)
- Activating location information capabilities and designating local crisis centers as public safety answering points (PSAPs) can reduce routing mismatches and provide life-saving pathways to care.
Location information for 988 calls ensures individuals will be routed to the crisis center nearest to their physical location.
- Like 911, the Lifeline provides immediate assistance, yet telecommunications service providers are unable to offer accurate caller location at this time.
- The Lifeline currently routes calls based on area code. With over 80% of calls placed by cell phone and the mobility of these wireless devices, a number’s area code may not correctly reflect the caller’s actual location.
- With the current area code routing, states also may experience challenges in gathering accurate metrics of usage for their state. This can affect the understanding of the crisis intervention needs and resources within a state.
Individuals receive better support when connected with their community’s crisis center.
- Crisis counselors who are more familiar with their community’s unique stressors (i.e. local events, recognizable locations) may be able to build a trusting connection with callers more quickly.
- Local centers are able to provide connections to and knowledge of local resources and services, including follow-up care, that reduce the risk of suicidality in individuals in crisis.
In the rare cases where emergency services may be deployed, geolocation would reduce delays in identifying the physical location of an individual needing intervention.
- Almost 90% of callers interviewed 9 days on average after the call reported that the Lifeline helped stopped them from killing themselves.
- Emergency services are utilized in only 2% of all calls answered by the Lifeline, in instances where someone is in immediate danger of harming themselves or others. At those times, every minute counts.
- Location information could be the difference between life and death for hundreds of thousands of people annually with 988. Vibrant Emotional Health, administrator of the Lifeline, estimates between 6-12 million individuals will utilize the new number in its first year and as many as 40 million by year five.
Privacy is critical to the protection of individual callers who utilize the Lifeline and 988.
- Calls to the Lifeline are confidential and require a court order for disclosure.
- With geolocation, 988 will continue to protect the privacy and confidentiality of callers. Crisis counselors are required to use the least invasive intervention necessary, while making every reasonable effort to ensure the safety of the caller.
Providing location information for 988 calls outweighs any associated costs for the reasons above.

Geolocation and 988

Geolocation Talking Points

Location information is identified as a key component for best practices and guidelines for behavioral health crisis care by the Substance Abuse and Mental Health Administration (SAMHSA). (https://www.samhsa.gov/sites/default/files/national-guidelines-for-behavioral-health-crisis-care-02242020.pdf)

Activating location information capabilities and designating local crisis centers as public safety answering points (PSAPs) can reduce routing mismatches and provide life-saving pathways to care.

Location information for 988 calls ensures individuals will be routed to the crisis center nearest to their physical location.

Like 911, the Lifeline provides immediate assistance, yet telecommunications service providers are unable to offer accurate caller location at this time.

The Lifeline currently routes calls based on area code. With over 80% of calls placed by cell phone and the mobility of these wireless devices, a number’s area code may not correctly reflect the caller’s actual location.

With the current area code routing, states also may experience challenges in gathering accurate metrics of usage for their state. This can affect the understanding of the crisis intervention needs and resources within a state.

Individuals receive better support when connected with their community’s crisis center.

Crisis counselors who are more familiar with their community’s unique stressors (i.e. local events, recognizable locations) may be able to build a trusting connection with callers more quickly.

Local centers are able to provide connections to and knowledge of local resources and services, including follow-up care, that reduce the risk of suicidality in individuals in crisis.

In the rare cases where emergency services may be deployed, geolocation would reduce delays in identifying the physical location of an individual needing intervention.

Almost 90% of callers interviewed 9 days on average after the call reported that the Lifeline helped stopped them from killing themselves.

Emergency services are utilized in only 2% of all calls answered by the Lifeline, in instances where someone is in immediate danger of harming themselves or others. At those times, every minute counts.

Privacy is critical to the protection of individual callers who utilize the Lifeline and 988.

Calls to the Lifeline are confidential and require a court order for disclosure.

With geolocation, 988 will continue to protect the privacy and confidentiality of callers. Crisis counselors are required to use the least invasive intervention necessary, while making every reasonable effort to ensure the safety of the caller.

Providing location information for 988 calls outweighs any associated costs for the reasons above.