Kari's Law, RAY BAUM'S Act and E911: what a small office must do

Why these laws exist

In 2013, Kari Hunt was killed in a motel room in Marshall, Texas. Her nine-year-old daughter tried to call 911 from the room phone four times. The calls never went through, because the motel's phone system needed a 9 before any outside number, and she did not know that.

Congress passed Kari's Law in 2018. The same year, Section 506 of RAY BAUM'S Act asked the FCC to make sure 911 calls carry a location that responders can act on. In August 2019 the FCC adopted the rules that put both into effect. They are in Part 9 of the FCC's rules.

Which phone systems the rules cover

Both laws apply to a multi-line telephone system, or MLTS. The FCC describes these as the systems typically found in office buildings, campuses and hotels: one system, many phones. A cloud PBX serving an office is one. So is an on-premises PBX or key system.

The rules are forward-looking. They apply to a system that was manufactured, imported, offered for first sale or lease, first sold or leased, or installed after February 16, 2020. A system installed on or before that date is exempt from the federal rules, though the law leaves state authority over emergency communications in place.

The duties fall on two groups:

• Manufacturers, importers, sellers and lessors of the system.
• Installers, managers and operators of the system.

A business that runs its own phone system is a manager or operator of it. That is why the rules matter to an office, not only to phone vendors.

Kari's Law: direct dialing and notification

Kari's Law has two requirements. Both took effect on February 16, 2020.

Direct dialing

A user must be able to dial 911 from any phone on the system without any prefix, code or post-fix, including a trunk-access digit such as 9, even if the system requires that digit for other outside calls.

For the system's maker and seller, that means shipping it pre-configured so that, properly installed, 9-1-1 just works. For the installer, manager and operator, it means keeping it configured that way.

Notification

When a 911 call is made, the system must send a notification to a central location on site, or to a person or organization anywhere, where someone is likely to see or hear it. The point is to help first responders get into the building and find the caller.

The notification must:

• be sent at the same time as the 911 call, where technically feasible;
• not delay the 911 call; and
• include that a 911 call was made, a valid callback number, and the location information the system sends to the 911 center, where feasible.

The FCC's examples of a notification are an on-screen message with an alarm on a security desk computer, a text message to a phone, or an email to an administrator.

This duty applies only if the system can be configured to notify without an improvement to its hardware or software. A system that can do it must be set up to do it.

RAY BAUM'S Act: dispatchable location

Section 506 of RAY BAUM'S Act is about where the call comes from.

A dispatchable location is the validated street address of the caller, plus the additional information, such as suite, apartment, floor or room, needed to find them. "123 Main Street" is not enough for a six-story building. "123 Main Street, Suite 410" is.

The FCC set two deadlines for multi-line systems, depending on the device:

The same two groups are responsible. A maker may not sell a system that cannot do this once properly installed. An installer may not install one that is not configured to be programmed with and convey the location. A manager or operator may not run one that does not convey it.

For a small office the practical point is simple. Every phone, including a softphone on a laptop, needs an address on file that would get an ambulance to the right door, and that address has to change when the phone does.

What the FCC requires of your VoIP provider

Separately from Kari's Law and RAY BAUM'S Act, the FCC's E911 rules bind every interconnected VoIP provider: a service that lets you call and be called on the ordinary phone network over the internet, which is what a cloud PBX is. The rules are in 47 CFR § 9.11. In the FCC's consumer-guide summary, a provider must:

• provide 911 to every customer as a standard, mandatory feature, with no opt-out;
• obtain the customer's physical location before service starts, and give the customer one or more easy ways to update it when it changes;
• send every 911 call, with a callback number and the registered location, to the right 911 center;
• make sure customers clearly understand any limits on their 911 service, and distribute warning labels to place on or near the equipment where 911 may be limited or unavailable;
• obtain and keep each customer's acknowledgement that they understand those limits.

The rule itself (§ 9.11(b)) adds the dates: these location duties apply from January 6, 2021 for fixed services and January 6, 2022 for non-fixed services. For a non-fixed service, which can be used from more than one place, the provider must either deliver an automated dispatchable location where technically feasible, or rely on a Registered Location that the customer gave before service began and can update at will, or provide alternative location information, or route the call to a national emergency call center.

The limits the rule says customers must be told about include moving the equipment to a new place, a broadband failure, loss of electrical power, and delays in getting the location into the 911 database.

The limits of VoIP 911, and what to do about them

The FCC's consumer guide is blunt about where VoIP 911 can fail:

• A call may reach the wrong 911 center, or an administrative line that is not staffed after hours, if the registered location is stale.
• A call may connect but not carry the number or location automatically.
• The service may not work in a power cut, or when the internet is down or overloaded.

Its advice is the same for any office:

1. Give your provider an accurate physical address, with suite or floor.
2. Know how to update it, and update it promptly when anything moves.
3. Understand the limits of your 911 service and tell the people who use the phones, including visitors and anyone who covers the front desk.
4. Keep a backup: a charged mobile phone, a battery for the network equipment, or a traditional line.

A checklist for a small office

Work through this once, then again whenever the office changes.

How this works on PBXflex

On PBXflex, the E911 address is registered per extension, in the app. Each person's extension carries its own address, so a desk phone in suite 410 and a colleague working from home can each have the address responders need. When someone changes desks, moves offices or starts working from home, update that extension's E911 address.

The security page lists what else PBXflex does with credentials, E911 and texting rules. The 911 fees that may appear on a phone bill are explained in the cost guide.

This guide summarizes public FCC rules as they read on the date shown at the top. It is not legal advice. For your own obligations, read the sources below or ask a lawyer.