Since becoming operational in 2022, the short code telephone number 988 has been a literal lifesaver with over 10 million callers reaching out with hope of stopping human suicides. With this success, system expansions have been proposed to make it more effective and save even more individuals. The latest proposition – georouting 988 texts to more localized suicide crisis centers – has generated broad support among most interested parties.
If there is any concern or reluctance to georouting 988 texts, it primarily rests with whether the government should impose mandates to execute the necessary steps. This is especially true when the technological specs haven’t been fully developed or adopted by industry yet. Indeed, government requirements could be unnecessary and potentially counterproductive. To the extent that increased precision of 988 for texts provided by georouting is appropriate, the private sector should maintain maximum flexibility over the when and how.

By way of background, there is considerable data that certain demographics, like youth, have a greater reliance on the billions of U.S. texts sent per day than traditional communications technologies. These groups also tend to experience higher rates of suicide than others or the national average. As a partial system enhancement, the Federal Communications Commission (FCC) recently proposed to impose a 988 georouting requirement for select texts.1 Specifically, certain wireless providers would be required to support georouting for Short Message Service (SMS) and potentially other text messages to the 988 system.
The good news is the relevant participants are already at work planning for the georouting of 988 texts. That is, the collection of technology companies (i.e., wireless providers, technology vendors, and data managers) as well as the 988 Lifeline Administrator, Vibrant, and the Substance Abuse and Mental Health Services Administration (SAMHSA) currently are discussing the best ways to make georouting of texts happen, including the technical requirements and timelines. From a good-government viewpoint, this should be seen as a major victory. Letting that process play out – without artificial deadlines or technological dictates by the government – is the best mechanism to achieve the end goal, which should remain focused on improving the 988 system to help needed individuals who are contemplating suicide.
Alternatively, the Commission could try to strong arm or bully the 988 community via regulations to generate some type of nominal press achievement. Despite the current open proceeding suggesting doing just that, it seems doubtful that a new FCC will want to pursue such a course of action given the potential for negative consequences. The notion that only FCC public safety mandates will result in project completion has been disproved time and time again. In fact, there is a litany of examples in which the FCC imposed technological mandates before the technology was developed or the participants had coalesced around the proper solution. Case in point is the FCC’s so-called “Audible Crawl” rule for television broadcasters that was adopted in 2015 but has been waived repeatedly for nearly 10 years. In that instance, the technology “does not exist” but the mandate remains and has led broadcasters to cease providing certain visual content to avoid potential enforcement exposure.2
The Commission does not possess a crystal ball. With a reasonable level of uncertainty as to when georouting for 988 texts could be technically operational and deployed, the Commission would be wise to assign staff to monitor the process and maintain vigilance. Nothing is to be gained by setting arbitrary requirements and/or deadlines. Moreover, doing otherwise assumes there must be bad faith among participants actively seeking solutions for georouting 988 texts. Yet, these are the same entities that have delivered 988 improvements in the past.
Recognizing that public safety concerns often generate a sympathetic ear among policymakers, there is a slight chance the FCC may deny these pleas for reasonableness. In such circumstances, any further Commission action on this subject should abide by two principles. First, the Commission should utilize the existing 988 infrastructure. This ensures a unified approach whereby all texts are received and processed by the Lifeline Administrator. It also allows traffic to be sifted through effective filters so certain texts for particularly sensitive groups (e.g., veterans) that may need and deserve unique assistance go to specially trained personnel. Uniformity would also complement Commission decisions from just three months ago on georouting of 988 wireless calls.
Additionally, any solution for georouting for 988 texts should not be based on the divergent and troubled 911 public safety model. Not only would that be a huge departure from the current architecture, thereby requiring a massive system redesign that the 988 Lifeline Administrator has warned against, it also would seem to open a major privacy exposure point for those texting. Likewise, 911 systems, known for being decentralized, have shown fissures because of old technology that still needs to be modernized nationwide and its incompatibility with the unified 988 approach. The private sector is actively cooperating to bring forward georouting for 988 texts – in the absence of government mandates. Everyone working together to promote greater effectiveness of the 988 system shouldn’t be disrupted by ideas promulgated by an exited Commission.
Michael O’Rielly is a Senior Fellow at The Media Institute and member of the Institute’s First Amendment Advisory Council. A former Commissioner of the Federal Communications Commission, he is President of MPO Consulting, Inc., based in Arlington, Va.
- Federal Communications Commission, Third Report and Order and Notice of Proposed Rulemaking, October 2024. https://www.fcc.gov/document/fcc-adopts-rules-requiring-georouting-all-wireless-calls-988-0. ↩︎
- National Association of Broadcasters, Petition for Rulemaking and Extension of Waiver of the National Association of Broadcasters, Nov. 15, 2024. https://www.fcc.gov/ecfs/document/1115662625005/1. ↩︎