Government Confirms Intent to Expand Call Tracing

SAMHSA doubles down on pushing peer warmlines to help initiate involuntary interventions

The Substance Abuse and Mental Health Services Administration is at it again, and I feel compelled to warn you. Last week SAMHSA posted a new draft document, the “2025 National Guidelines for a Behavioral Health Coordinated System of Crisis Care.” And SAMHSA’s deadline for public comments is already this Sunday, Dec. 15, 2024, at 11:59 p.m. ET.

Follow the link to see the guidelines and to comment. If you’re someone who works in or uses the crisis care system in any way, you may want to especially read those sections that touch on your areas of expertise. But to understand why I’m especially concerned about this document, read on.

Brief recap

A bit of background: Last week I wrote about SAMHSA’s companion draft document, the “Model Behavioral Health Crisis Services Definitions,” which itself had only a two-week public comment period. I wrote that it appeared that SAMHSA’s goal is to, while skirting public debate, “define” what crisis lines are in a way that could push all non-988 crisis lines, peer-run warmlines, and emotional support lines across America (there are hundreds) towards adopting 988Lifeline intervention policies. Specifically, the SAMHSA document seemed to recommend, amid an implied threat of loss of funding, that all non-988 helplines should begin routing some callers (anyone believed to be at “imminent risk”) to 911 or 988 for policing interventions that would potentially breach privacy, be implemented against the caller’s will, and result in forced detentions at psychiatric facilities.

I can now update that story. In response to my request for clarification, a SAMSHA representative confirmed my interpretation, finally emailing back, “The guidance document is recommending peer-run warmlines to develop relationships with 988 lines for referral purposes to address the need of callers that present with imminent risk that cannot be mitigated through safety planning or other interventions.” In other words, yes, the intention is to get all peer warmlines to help initiate involuntary interventions on callers. And the SAMHSA document made the same “recommendation” for all non-988 crisis lines and emotional support helplines as well.

Now, the new SAMHSA “guidelines” cover a lot of the same territory as last week’s “definitions” document. In more detailed ways, they “establish overarching principles for behavioral health crisis system transformation” while informing standards of practice—including for crisis lines, mobile mental health services, and facilities like crisis stabilization centers and psychiatric hospitals.

And these new guidelines double down on SAMHSA’s “recommendation” that all non-988 crisis lines, peer-run warmlines, and emotional support lines should essentially adopt 988Lifeline’s aggressive involuntary intervention policies—a position elaborated on further in two key, referenced documents.

As a key justification for pushing peer-run warmlines to help implement these interventions, the SAMHSA document states that doing so will be especially effective for intervening on children and youth against their will “as they may be more likely to seek support from a peer-operated warmline.”

In “988 Convening Playbook: Public Safety Answering Points (PSAPS),” details about how the geolocating of callers should be implemented by each 911 center, at the request of crisis lines, are described. And the “National Guidelines for Behavioral Health Crisis Care: Best Practice Toolkit” clarifies that such policing interventions should only be a “last resort” option—"except for” in some circumstances. And the document then proceeds to list a lot of vague circumstances where initiating policing interventions against a caller’s will should essentially be the first or second option.

As a key justification for pushing peer-run warmlines in particular to implement these intervention practices, the SAMHSA document states that this practice will be especially effective for finding and detaining children and youth in crisis “as they may be more likely to seek support from a peer-operated warmline.” A similar tendency to seek out peer-run warmlines is likely more common among many other communities of higher vulnerability, too.

a long, winding wire that connects a police officer and a child

This could be devastating. It will increase the number of people, including unwitting children, subjected to these policies that already result in hundreds of thousands of callers to crisis lines every year being subjected to often-frightening interventions such as policing visits and forced hospitalizations. It could potentially undermine political and public support and funding to those crisis lines, warmlines, or emotional support helplines in America that refuse to help initiate these policing interventions. And it could ultimately make it impossible for anyone anywhere in America to safely call any kind of crisis or emotional helpline without fear of a police visit and unwanted trip to a psychiatric facility.

My own recommendations

SAMHSA should remove any recommendations or suggestions from the guidelines and related reference documents that peer-run warmlines or emotional support helplines should implement procedures for contacting 911 or 988 to enact involuntary interventions on callers. On the contrary, all crisis lines and peer-run warmlines that do not engage in non-consensual interventions should be supported and celebrated as vital alternatives to meet people’s needs who require absolute confidentiality.

Furthermore, overarching principles of crisis lines and other crisis services should include proactive public transparency about all policies and practices—especially with respect to often-traumatizing non-consensual interventions and unauthorized sharing of personal information such as recorded conversations. And crisis services should track and publicly report data on involuntary interventions while working to reduce and eliminate involuntary interventions. Finally, all crisis services should implement robust complaint and appeal processes that include oversight and reporting by independent third parties.

Submit your own comments to SAMHSA here.

I’ve been leaving comments open on all posts for all subscribers, so please feel welcome to share your thoughts with me and others.

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