The Privacy-Location Paradox: A Technical Blueprint for 988 Georouting

In 2020, the U.S. introduced 988 as a short code for reaching the Nationwide Suicide and Crisis Lifeline, streamlining access to support services for those experiencing a mental health crisis. As 988 continues to evolve, a new challenge arises: how to balance the need to route calls to the most appropriate – typically, the local – crisis center, while protecting expectations of caller privacy. The Federal Communications Commission's recent order marks a critical step toward modernizing the 988 system, ensuring that individuals in crisis can access care quickly without sacrificing their privacy. 

The need to improve 988 call routing

988 is designed to provide easier and more immediate access to mental health professionals. To be the most effective, calls must be directed based on the caller's physical location, ensuring that the person receives timely support relevant to their local resources.

Until now, however, the routing method for 988 has largely depended on the area code of the caller’s phone number and not where they are located. This method is problematic in today's mobile society, where people often keep their phone number when moving to a different state, and people travel around the country with greater frequency. As a result, a call from a phone with a California area code will be routed to a crisis center in California, even if the caller is physically in New York. Routing needs to be improved. The situation has gotten better recently, as the largest wireless carriers are initiating “georouting” for 988 calls.

The privacy-location paradox

Striking the right balance between providing accurate data to permit effective routing and protecting the caller’s expectation of privacy is the crux of the privacy-location paradox. While providing sufficient data is critical for the efficient routing of 988 services, it raises significant privacy concerns. Mental health crises involve sensitive information, and there is a reasonable fear that sharing precise location data could become a disincentive for people to call 988, or worse, expose personal data to misuse. Further, as mental health crises may involve issues such as abuse or domestic violence, the need to keep location information confidential is paramount.

The FCC’s 2024 Order: Georouting data with privacy protections

To address these concerns, the FCC adopted a pivotal order in October 2024, aimed at improving the routing of 988 calls. 

Key aspects of the FCC order include:

1. Georouting Requirements: The FCC mandated that nationwide wireless carriers must begin routing 988 voice calls to the Lifeline Administrator with “georouting data,” when available, using cell-based location technology that aggregates cell site or base station data “to a level that will not identify the location . . . of the handset” so as to protect expectations of caller privacy. Nationwide wireless carriers have 30 days after the rule becomes effective to fully implement georouting. Non-nationwide carriers have 24 months.
2. Privacy Safeguards: The FCC's order emphasizes that the location of the 988 caller should not be revealed or included in the call flow. Wireless carriers must ensure this. 
3. Routing Through 988 Lifeline Administrator: The FCC continues to require wireless carriers to route both voice calls and texts directly to the 988 Lifeline Administrator, but carriers will now be able to route to 988 without the need for translation to the ten-digit, toll-free number.
4. Interaction of 988 and 911: The FCC stated that the interaction between 988 and 911 is outside the scope of the current rulemaking but acknowledged that there are several efforts underway to address how 988 and 911 should interoperate. In the immediate future, for the small number (about 3%) of 988 calls that require an emergency response, the ability to dispatch emergency response relies on a 988 caller voluntarily providing physical location.
5. Deferral of Georouting for Other Use Cases: For the time being, carriers are not required to georoute text-2-988 or calls made while roaming or on other platforms and may continue to route based on NPA/NXX.

Looking ahead to a more secure 988 system

Complying with the FCC’s new georouting rule requires a detailed, technical approach. To transition from area code-based routing to georouting, the 988 telecommunications infrastructure must integrate some type of location-based data services, while protecting caller privacy.

The most efficient way to meet this objective is for wireless carriers to transmit approximate cell site data overlaid with another routing boundary to further obscure precise location – such as wire center boundaries or FIPS code. What the carrier ultimately passes through is a destination code that will allow the 988 Lifeline Administrator to identify the nearest crisis center without passing through caller location data in the call flow. Carriers can either build this capability in-house or look to someone like their 911 vendor that will leverage existing technology and infrastructure. 

More work needs to be done to apply georouting to other use cases, such as text-2-988 and roaming. When the Commission adopted the georouting requirement for wireless voice calls to 988, it also started a further inquiry into solutions for georouting texts-2-988. The Commission proposed to require “covered text providers” – basically, any text provider that permits “interconnection,” meaning they allow users to text any number in the U.S. – to support georouting for SMS text messages to 988.

If the 988 Lifeline becomes able to accept other text formats in the future, the Commission said it anticipates that there would be a need to georoute those communications, too. Some technology providers are already refining solutions for this. Georouting for roaming calls to 988 is not yet on the table, at least as far as FCC requirements. 

The public safety community, which operates 911 and dispatches emergency response, sees an opportunity to improve the security and reliability of the 988 network by allowing states to request that 988 calls be routed through advanced, Next Generation 911 infrastructure that many states are already deploying.

This would likely mean that calls would not necessarily be routed through the 988 Lifeline Administrator. The FCC did not entertain this option in its recent order, opting instead to focus on how to improve care as quickly as possible for the greatest number of people. This issue will, no doubt, be the subject of future discussions between the 988 and the 911 communities. 

One thing is certain – it is critical to the mental health community that callers maintain control over what information they convey, especially their physical location, and that callers to 988 understand that their information and location are protected from disclosure without their consent. With the right blend of technical expertise and ethical oversight, the future of mental health crisis intervention can offer both protection and precision, navigating the complex privacy-location paradox with innovation and care.

Jerry Wilke is the Director of Sales Engineering at Intrado, a telecom company that provides emergency communication services and technology to public safety agencies and telecom service providers. This Expert Opinion is exclusive to Broadband Breakfast.

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