988 georouting, done with FIPS codes instead of location

ATIS’ Emergency Services Interconnection Forum has published ATIS-0500049, GeoRouting for 988 Voice Calls, which specifies how carriers route 988 Lifeline calls to the right local crisis center. The mechanism is deliberately blunt: state and county-level FIPS codes carried in existing SS7 and SIP signaling, replacing area-code-based routing, “without using precise geolocation data.” SAMHSA, the 988 Lifeline administrators, Vibrant, and Mosaicx all fed into it.

The design choice is the story. Area-code routing fails the obvious modern case — the caller whose number was issued three states from where they live — and the reflexive fix would have been to reach for the same handset location machinery that 911 has spent a decade refining. ESIF went the other way and picked the coarsest resolution that solves the routing problem, then stopped. County-level granularity is enough to reach the right crisis center and not enough to tell anyone where a person in crisis is standing.

That restraint is unusual enough to note, and it’s a useful reference point when the next proceeding asks for location data because location data would be convenient. The privacy-preserving version of a signaling feature usually exists; it just requires someone to specify it deliberately rather than inherit the maximal one. Carriers implementing to meet the FCC’s georouting requirements now have a standard that lets them comply without building a location pipeline they’d then have to protect.