E-9-1-1 Compliance: A Hard Deadline for Softphones

January 6, 2022 is Compliance Day

Giving everyone the ability to dial 9-1-1 directly are what Kari’s Law and RAY BAUM’s Act are all about. Passed in 2018 and 2019 (respectively), both have staggered compliance deadlines that began in 2020. The last compliance deadline is January 6, 2022. Here’s what you need to know. But first, a little background.

What is Kari’s Law?

Kari’s Law can save lives by enabling you to call 9-1-1 directly without have to dial a prefix, such as 9, to get an outside line. Kari’s Law ensures that in an emergency, anyone — children, guests, employees — not familiar with the organization’s phone system can pick up a phone and dial 9-1-1 with no impediments.

Makes sense, right? But it wasn’t like that until 2020 and it took a tragedy to make it happen. The law also requires the 9-1-1 call to send an emergency alert, such as a phone call, text, email, or an alarm, to on-site personnel notifying them of the call and caller’s location. This law typically affects organizations in office buildings, campuses, hotels, hospitals, — basically anywhere and everywhere you can’t dial an outside line directly.

Kari’s law applies to all organizations with a MLTS (multi-line telephone system) that is manufactured, imported, offered for first sale or lease, first sold or leased, or installed after February 16, 2020. Even if you’re MLTS is was installed prior to 2020, you may still need to comply. The law says “if the system is able to be configured to provide the notification without an improvement to the hardware or software of the system.” Basically, this means that if your phone system can be compliant, you need to enable that function.

What is RAY BAUM’S Act?

RAY BAUM’s Act* requires that 9-1-1 calls include dispatchable information so first responders can find the emergency caller.

What is a Dispatchable Location?

Section 506 of RAY BAUM’s Act (March 23, 2018) defines dispatchable location requirements with different deadlines depending on the type of device. It states that the “dispatchable” location contain “sufficient information to locate the caller adequately.” (This definition has caused some to question what sufficient actually means regarding different phone systems and building configurations.)

A dispatchable location means a street address, but it needs to be more specific than indicating the front lobby or second floor. It should detail section, floor, suite, room and office numbers, and even the exact phone extension location of the emergency caller. An example may be NE corner, second floor, suite 2001, office 3, extension, 2013.

Obviously dispatchable location information depends on the environment. The previous example is very specific, and it needs to be. But a call from the second floor, without the proper provisioning, could possibly include a hundred users in a MLTS with DID (Direct Inward Dialing). There would be no way of knowing the caller’s specific location or to call back without an extension number.

Your responsibility is to make sure your MTLS, phones, and other devices, are equipped to provide the necessary dispatch location information. All newer systems can do this. Older systems may be easily upgradeable.

But the devil is in the details. It takes work to map all user endpoints and inventory all the phones and devices you have. It’s your responsibility, and the law, to make sure that if anyone calls 9-1-1 from a device on your MLTS network, they get through and dispatchable information is conveyed.

What’s Types of Phones Need to Comply?

There are two January 6 compliance dates you need to be aware of: 2021 and 2022. Here’s what you need to know about each.

Hard phones: January 6, 2021
This is when fixed MTLS, interconnected VoIP, telephone, and telephony relay services had to comply with the location dispatch information rule. Hard (static or tangible) phones include desktop phones, phones in conference rooms or lobbies, phones in contact centers, phones or devices used by the deaf or hard-of-hearing, and phones that can be used on-premise or taken to another (home) office.

Softphones: January 6, 2022
This deadline, while it covers the same telephony services, applies to softphones or nomadic (non-static or non-fixed) phones and devices. A nomadic phone is basically any portable laptop, tablet, or smartphone that is on- or off-premise and requires dynamic location routing. For that reason, softphone compliance is more complex and presents more challenges than hard phone compliance. Softphone compliance will also involve network components, such as Wi-Fi access points to be configured with a dispatchable location for mobile phones to capture.


How Does Nomadic 9-1-1 Work?

Nomadic devices, such as a mobile phone, can access dispatchable information from network components, such as Wi-Fi access points. The devices can capture the location of the access point and use that as a dispatchable location.

What about Work-from-Home/Remote Employees

Who would have thought this would become such an important question? No one prior to 2020. WFH and remote employees may be off-site, but they are not out of mind when it to comes to compliance. COVID-19 sent people home, but it did not exempt remote employees from 9-1-1 compliance. Just how are people covered and how can the enterprise collect dispatchable information?

Many MLTS platforms, such as Microsoft® Teams, Zoom Phone, and others, meet compliance requirements for dynamic, nomadic non-fixed VoIP systems. Traditional on-premise systems may be outfitted with solutions that enable off-premise users to enter the address of their current location.

If no location is available, most 9-1-1 call centers will route the call to a nationwide call center to try to determine location.

What about Contact Centers?

Contrary to what many believe, contact centers are not exempt and need to comply with RAY BAUM’s Act. The Act applies to all interconnected VoIP services, including contact centers with hard phones. If contact center employees use softphones, such as a laptop, they must be compliant January 6, 2022.

On-Premise vs. Cloud Systems

Good question. The simple answer is yes. If you’re providing a phone system to your employees, no matter if it’s on-site or in the cloud, it needs to comply.

While the regulations may seem complicated, you have help. For more information about Kari’s Law and RAY BAUM’s Act and how to ensure your compliance, please contact us at 855-324-9909 or email us at [email protected]

For more information about what Kari's Law is and 911 compliance regulations surrounding soft/mobile phones, see these blogs: Kari's Law and Ray Baum's Act Compliance Information and 911: From Where's the Fire to Wherever You Are.

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(*All capital letters is correct and not a mistake.)
You may also be interested in this guide. 9 Things to Know About 9-1-1 Compliance

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