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KARI'S LAW AND RAY BAUM'S ACT
911 Direct Dialing, Notification, and Dispatchable Location Requirements
Multi-line Telephone Systems 911 Direct Dialing, Notification, and Dispatchable Location Requirements

Kari's Law and RAY BAUM'S Act

In August 2019, the Commission adopted rules implementing two federal laws that strengthen emergency calling: Kari's Law and Section 506 of RAY BAUM'S Act.

Kari's Law Summary

Kari's Law ensures that anyone can reach a 911 call center when dialing 911 from an MLTS. The law is named in honor of Kari Hunt, who was killed in a motel room by her estranged husband in 2013. Her daughter tried to call 911 four times, but the calls never went through because the motel's phone system required dialing "9" before any call to secure an outbound phone line.

Under the statute, which went into effect on February 16, 2020, MLTS vendors and manufacturers must configure new phone systems to support direct dialing 911. The system must also send a notification to a central location on- or off-site, such as a front desk or security kiosk. The notification will provide an alert that a 911 call was placed and include a callback number and information about the caller's location.

Kari's Law Compliance Date

Kari's Law compliance deadline date for organizations with MLTS must comply with the mandates of Kari's Law by February 16, 2020.

Any business or agency who does not comply with Kari's Law 911 legislation could face a fine of up to $10,000 in addition to other penalties, including a daily fine of up to $500 each day they are found not in compliance.

Kari's Law – Direct Dialing and Notification for MLTS

Congress responded by enacting Kari's Law in 2018. Kari's Law requires direct 911 dialing and notification capabilities in multi-line telephone systems (MLTS), which are typically found in enterprises such as office buildings, campuses, and hotels. The statute provides that these requirements take effect on February 16, 2020, two years after the enactment date of Kari's Law. In addition, Kari's Law and the federal rules are forward-looking and apply only with respect to MLTS that are manufactured, imported, offered for first sale or lease, first sold or leased, or installed after February 16, 2020.

Under the statute and the Commission's rules, MLTS manufacturers and vendors must pre-configure these systems to support direct dialing of 911—that is, to enable the user to dial 911 without having to dial any prefix or access code, such as the number 9. In addition, MLTS installers, managers, and operators must ensure that the systems support 911 direct dialing.

The Commission's rules also implement the notification requirement of Kari's Law, which is intended to facilitate building entry by first responders. When a 911 call is placed on a MLTS system, the system must be configured to notify a central location on-site or off-site where someone is likely to see or hear the notification. Examples of notification include conspicuous on-screen messages with audible alarms for security desk computers using a client application, text messages for smartphones, and email for administrators. Notification shall include, at a minimum, the following information:

  1. The fact that a 911 call has been made;
  2. A valid callback number; and
  3. The information about the caller's location that the MLTS conveys to the public safety answering point (PSAP) with the call to 911; provided, however, that the notification does not have to include a callback number or location information if it is technically infeasible to provide this information. (47 CFR § 9.3.)

Kari's Law Compliance date (MLTS direct dialing and notification) and Exemption for Legacy MLTS: Kari's Law and the Commission's rules are forward-looking and do not apply with respect to any MLTS that is manufactured, imported, offered for first sale or lease, first sold, or leased, or installed on or before February 16, 2020. (See 47 CFR § 9.17(b).

All other MLTS (i.e., systems manufactured, imported, offered for first sale or lease, first sold, or leased, or installed after February 16, 2020) must meet the following compliance date:

Feb. 17, 2020: *

MLTS manufacturers, importers, sellers, and lessors:

  1. May not manufacture or import for use in the United States, or sell or lease or offer to sell or lease in the United States, an MLTS, unless the system is pre-configured so that when it is properly installed in accordance with the MLTS rules, a user may directly initiate a call to 911 from any station equipped with dialing facilities, without dialing any additional digit, code, prefix, or post-fix, including any trunk-access code such as the digit 9, regardless of whether the user is required to dial such a digit, code, prefix, or post-fix for the other calls. (47 CFR § 9.16(a)(1).)

MLTS installers, managers, and operators:

  1. May not install, manage, or operate for use in the United States an MLTS, unless the system is configured so that a user may directly initiate a call to 911 from any station equipped with dialing facilities, without dialing any additional digit, code, prefix, or post-fix, including any trunk-access code such as the digit 9, regardless of whether the user is required to dial such a digit, code, prefix, or post-fix for other calls. (47 CFR § 9.16(b)(1).)
  2. Shall, in installing, managing, or operating an MLTS for use in the United States, configure the system to provide MLTS notification to a central location at the facility where the system is installed or to another person or organization regardless of location, if the system is able to be configured to provide the notification without an improvement to the hardware or software of the system. (47 CFR § 9.16(b)(2).) MLTS notification must meet the following requirements:
  • It must be initiated at the same time of the 911 call event, if it is technically feasible to do so; and
  • It must not delay the call to 911; and
  • It must be sent to a location where someone is likely to see or hear it. (47 CFR § 9.16(b)(2).)

RAY BAUM'S Act Summary

RAY BAUM'S Act emphasizes the importance of making dispatchable location information from all 911 calls available to Public Safety Answering Point's (PSAPs), regardless of the technological platform used. The FCC states "dispatchable location means a location delivered to the PSAP with a 911 call that consists of the validated street address of the calling party, plus additional information such as suite, apartment or similar information."

RAY BAUM'S Act Compliance Date

RAY BAUM'S Act deadline date for provision of dispatchable location from MLTS on-premises, fixed devices must comply with the mandates of RAY BAUM'S Act by January 6, 2021.

RAY BAUM'S Act deadline date for provision of dispatchable location or alternative location information from MLTS on-premises, non-fixed devices, and off-premises devices must comply with the mandates of RAY BAUM'S Act by January 6, 2022.

Any business or agency who does not comply with RAY BAUM'S Act could face a fine of up to $10,000 in addition to other penalties, including a daily fine of up to $500 each day they are found not in compliance.

RAY BAUM'S Act - Dispatchable Location For MLTS

Under Section 506 of RAY BAUM'S Act, the Commission has adopted rules to ensure that "dispatchable location" is conveyed with 911 calls to dispatch centers, regardless of the technological platform used, including 911 calls from Multi-Line Telephone System (MLTS). Dispatchable location means a location delivered to the PSAP with a 911 call that consists of the validated street address of the calling party, plus additional information such as suite, apartment, or similar information necessary to adequately identify the location of the calling party. For further information on dispatchable location requirements applicable to non-MLTS, including compliance timelines, see the Dispatchable Location web page.

Compliance Dates (MLTS Dispatchable Location): The Commission's dispatchable location rules for MLTS apply to all MLTS that are manufactured, imported, offered for first sale or lease, first sold or leased, or installed after February 16, 2020. While the dispatchable location rules apply to the same entities subject to Kari's Law, the Commission established separate deadlines for MLTS to come into compliance with the dispatchable location rules. As outlined below, MLTS are subject to compliance deadlines of January 6, 2021 and January 6, 2022, depending on the nature of the device from which the MLTS 911 call originates.*

2021

Jan. 6, 2021

Provision of dispatchable location from MLTS on-premises, fixed devices:

  • On-premises, fixed devices associated with an MLTS must provide automated dispatchable location with 911 calls.
Dispatchable location obligations for MLTS manufacturers, importers, sellers, lessors, installers, managers, and operators:

  • MLTS manufacturers, importers, sellers, and lessors may not manufacture, import, sell, lease, or offer to sell or lease an MLTS unless the system has the capability, after proper installation in accordance with the rules, of providing the automated dispatchable location of the caller to the PSAP with 911 calls from on-premises, fixed devices.
  • MLTS installers may not install a system unless it is configured so that it is capable of being programmed with and conveying the automated dispatchable location of the caller to the PSAP with 911 calls from on-premises, fixed devices.
  • MLTS managers and operators may not manage or operate a system unless it is configured so that the automated dispatchable location of the caller is conveyed to the PSAP with 911 calls from on-premises, fixed devices.
2022

Jan. 6, 2022

Provision of dispatchable location or alternative location information from MLTS on-premises, non-fixed devices and off-premises devices:

  • On-premises, non-fixed devices associated with an MLTS must provide automated dispatchable location to the appropriate PSAP when technically feasible; otherwise they must provide either dispatchable location based on end-user manual update, or alternative location information that meets the requirements below.
Alternative location option for MLTS on-premises, non-fixed devices:

  • Alternative location information may be coordinate-based, and it must be sufficient to identify the caller's civic address and approximate in-building location, including floor level, in large buildings.
  • Off-premises devices associated with an MLTS must provide to the appropriate PSAP automated dispatchable location if technically feasible; otherwise, they must provide either dispatchable location based on end user manual update, or enhanced location information that meets the requirements below.
Enhanced location option for MLTS off-premises devices:

  • Enhanced location information may be coordinate-based, and it must consist of the best available location that can be obtained from any available technology or combination of technologies at reasonable cost.
Dispatchable location obligations for MLTS manufacturers, importers, sellers, lessors, installers, managers, and operators:

  • MLTS manufacturers, importers, sellers, and lessors may not manufacture, import, sell, lease, or offer to sell or lease an MLTS unless the system has the capability, after proper installation in accordance with the rules, of providing the dispatchable location of the caller as specified in section 9.16(b)(3)(ii) and (iii) to the PSAP with 911 calls from on-premises, non-fixed devices and from off-premises devices.
  • MLTS installers may not install an MLTS unless it is configured so that it is capable of being programmed with and conveying the dispatchable location of the caller as specified in section 9.16(b)(3)(ii) and (iii) to the PSAP with 911 calls from on-premises, non-fixed devices and from off-premises devices.
  • MLTS managers and operators may not manage or operate an MLTS unless it is configured so that the dispatchable location of the caller as specified in section 9.16(b)(3)(ii) and (iii) is conveyed to the PSAP with 911 calls from on-premises, non-fixed devices and from off-premises devices.
*The Public Safety and Homeland Security Bureau is providing the above timeline to help regulated entities comply with the rules. This timeline does not reference all of the relevant rules, does not include the full text of the rules, and does not modify or supersede the specific text of any rule that is referenced. The Commission retains the discretion to adopt case-by-case approaches, where appropriate, that may differ from the approach in this timeline. Any decision regarding a particular regulated entity will be based on the statutes and any relevant rules.

**The new rules became effective on January 6, 2020, although the compliance deadlines for the rules vary. In addition, Sections 9.16(b)(3)(i), (ii), and (iii) of the rules contain information collections under the Paperwork Reduction Act (PRA). Compliance with these sections will not be required until after the relevant information collections are approved by the Office of Management and Budget. Following such approval, the Commission will publish a document in the Federal Register announcing the compliance dates for these requirements and will update this timeline as necessary to reflect these dates.

Resources

911 Requirements for MLTS – 47 C.F.R. Part 9, Subpart F

Frequently Asked Questions - MLTS FAQs

Small Entity Compliance Guide: https://www.fcc.gov/document/implementing-karis-law-and-section-506-ray-baums-act-0

The FCC will closely monitor any complaints about alleged violations of these 911 rules.

  • Public Safety Answering Points (PSAPs), also known as 911 call centers, and other public safety entities may request support from the Public Safety and Homeland Security Bureau and notify it of problems or issues affecting the provision of emergency services through the Public Safety Support Center.

Frequently Asked Questions

What is Kari's Law?
Kari's law is an amendment to the FCC's Communications Act that enables direct dialing of 9-1-1. It mandates that any multi-line telephone system (MLTS) allows users to dial 9-1-1 without having to dial a prefix, like 9,8, or 0. In other words, to dial 9-1-1, there's no extra 9 needed.

It also dictates that a notification is sent (e.g. floor and room number within a building) to security officials or building administrators for an MLTS, to rapidly dispatch assistance or first-aid, either through a text, an email, or a phone call.
What Are The Kari's Law requirements?
Kari's Law applies to multi-line telephone systems ("MLTS") "manufactured, imported, offered for first sale or lease, first sold or leased, or installed" after the compliance date of February 16, 2020. It requires:

REQUIRING A "PREFIX" WHEN CALLING 911 IS PROHIBITED
Locations with MLTS must remove any requirement that a caller dial "9", "8", or any other number or digits to reach an outside line to make a call to 911.

ON-SITE NOTIFICATIONS
When a 911 call is placed from an MLTS, a notification must be sent to on-site personnel, alerting them to the emergency. The notifications to the appropriate contact can take the form of phone calls, visual alerts on a monitor, audible alarms, text messages, and/or emails.
When Did Kari's Law Go Into Effect?
Kari's Law compliance date started on February 17, 2020
What Does Kari's Law Affect?
Kari's Law applies to multi-line telephone systems ("MLTS") "manufactured, imported, offered for first sale or lease, first sold or leased, or installed" after the compliance date of February 16, 2020.
What Does Kari's Law Have To Do With Call Location?
In addition to guaranteeing that anyone can direct dial 9-1-1 for help, Kari's Law, as well as the Ray Baum Act, aim to ensure that anyone calling 9-1-1 will be able to be found, no matter where they're calling from.

As we know, VoIP and mobile phones don't have a local address attached when they call 9-1-1, like a landline phone would, so it makes identifying the location of a call dependent on verbally relayed information. During an emergency, a caller might not know where they are, or be able to provide enough specific context to be easily found by first responders.

Kari's Law was passed alongside the Ray Baum Act to ensure that a dispatchable location is sent along to an Emergency Communications Center (ECC) when 9-1-1 is dialed through an MLTS, so that first responders will be better able to find callers in need.
How Will Kari's Law Change Public Safety?
By ensuring that MLTS phones no longer have to enter a prefix to dial 9-1-1, Kari's Law will expedite emergency calls and deliver help faster than ever to the occupants of enterprise-level buildings.

Whether they're school kids, travelers, office employees, or hotel workers, Kari's Law will not only avert any confusion they might experience in an emergency, it will help send accurate location data along to first responders.

Having access to precise location data revolutionizes our approach to public safety. First responders will save time searching for callers, and can instead focus their efforts on getting to the scene as fast as possible. Considering how many lives are lost each year because first responders couldn't find who they were trying to help, having access to this data will undoubtedly cut that number down.

What Is The RAY BAUM Act?
RAY BAUM's Act is broad in scope, but the aspect most focused on is Section 506 which refers to the rules adopted by the FCC requiring enterprises utilizing multi line telephone systems (MLTS) to provide automated dispatchable location for all 911 calls.

Dispatchable location information provided to the public safety answering point (PSAP) includes a valid civic address, plus other information such as building, floor, suite, or room number "necessary to adequately identify the location of the calling party." Dispatchable location can include "dynamic" or "nomadic" location information or more granular-level "fixed" location information.

What Are The RAY BAUM'S Act requirements?
  • Provision of dispatchable location from MLTS on-premises, fixed devices by the RAY BAUM'S Act compliance date of January 6, 2021
  • Provision of dispatchable location or alternative location information from MLTS on-premises, non-fixed devices and off-premises devices by the RAY BAUM'S Act compliance date of January 6, 2022.
When Is The RAY BAUM Act Effective Date?
  • RAY BAUM'S compliance date started on January 6, 2021 for provision of dispatchable location from MLTS on-premises, fixed devices.
  • RAY BAUM'S compliance date starts on January 6, 2022 for provision of dispatchable location or alternative location information from MLTS on-premises, non-fixed devices and off-premises devices.
What Does RAY BAUM'S ACT Affect?
The Commission's dispatchable location rules for MLTS apply to all MLTS that are manufactured, imported, offered for first sale or lease, first sold or leased, or installed after February 16, 2020.
Who is Ray Baum?
Ray Baum was a telecommunications champion and longtime friend of Energy and Commerce Committee GOP Leader Greg Walden (R-OR). Baum was an Oregon native who devoted his career to public service, serving as a commissioner and chair of the Oregon Public Utilities Commission (PUC), on the board of directors of the National Association of Regulatory Utility Commissioners (NARUC), and as chair of NARUC's Committee on Telecommunications. He joined then-Energy and Commerce Telecommunications and the Internet Subcommittee Chairman Walden's team as senior policy advisor, and then as staff director of the full committee under then-E&C Chairman Walden. He sadly lost his battle with cancer in February 2018
What Does RAY BAUM'S Act Have To Do With Call Location?
In addition to guaranteeing that anyone can direct dial 9-1-1 for help, Kari's Law, as well as the Ray Baum Act, aim to ensure that anyone calling 9-1-1 will be able to be found, no matter where they're calling from.

As we know, VoIP and mobile phones don't have a local address attached when they call 9-1-1, like a landline phone would, so it makes identifying the location of a call dependent on verbally relayed information. During an emergency, a caller might not know where they are, or be able to provide enough specific context to be easily found by first responders.

Kari's Law was passed alongside the Ray Baum Act to ensure that a dispatchable location is sent along to an Emergency Communications Center (ECC) when 9-1-1 is dialed through an MLTS, so that first responders will be better able to find callers in need.
How Will RAY BAUM's Act Change Public Safety?
Today's enterprise and campus environments consist of large, multi-story buildings with complex layouts. A first responder arriving at one of these buildings armed only with the main street address is unlikely to quickly find a 911 caller located in a 4th floor conference room.

RAY BAUM's Act establishes the concept of "dispatchable location" for Interconnected VoIP services and other 911-capable services. This more precise location information is critical to achieving successful emergency outcomes for calls that originate from multi-line telephone systems (MLTS).

Whether they're school kids, travelers, office employees, or hotel workers, Kari's Law will not only avert any confusion they might experience in an emergency, it will help send accurate location data along to first responders.

Having access to precise location data revolutionizes our approach to public safety. First responders will save time searching for callers, and can instead focus their efforts on getting to the scene as fast as possible. Considering how many lives are lost each year because first responders couldn't find who they were trying to help, having access to this data will undoubtedly cut that number down.
Who's Affected by Kari's Law and RAY BAUM's Act?
Both laws impact enterprises using multi-line telephone systems (MTLS), such as:

• Companies with offices in multiple locations
• Campuses–including K-12, universities, and colleges
• Hospitals
• Hotels
• Retail facilities
• Financial institutions
• Warehouses
What Is A PSAP?
PSAPs (Public Safety Answering Points) are responsible for receiving 911 calls and processing those calls according to a specific operating policy. You might think of these as a dedicated call center for answering emergency phone calls and dispatching appropriately.
What Is A Multi Line Telephone System?
A multi-line phone system lets you handle two or more calls simultaneously. It enables employees to place calls on hold, dial internal or external numbers, and return to the line.

Multi-line phones differ from phones with a single line that can only maintain one phone call at a time. Likewise, they have one phone number assigned to them. When the line is in use, callers will be directed to a voicemail or a busy signal.
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