Kari’s Law is named for Kari Hunt who was killed by her estranged husband in a motel room in Marshall, Texas in December of 2013. Ms. Hunt’s 9-year-old daughter had tried to dial 911 several times during the attack but was not able to because she did not know she had to first dial “9” to get an outbound line.

Through this tragedy, lawmakers realized there is a problem caused by many of the multi-line telephone systems typically found in hotels, offices, and universities. These systems require users to dial an additional digit to use an outside line — even when they are trying to call 911.

Congress enacted Kari’s Law in 2018. The legislation requires multi-line telephone systems (MLTS) to be configured so dialing 911 directly connects to public safety. MLTS phone systems are typically found in enterprises such as office buildings, campuses, and hotels. These requirements went into effect on February 16, 2020.

If your telephone system requires your employees and other users to dial a number to get an outside line, your business must comply with this law.

Fortunately, most of today’s newer telecom systems meet Kari’s Law. However, it’s important to verify your system works as required and that the emergency dispatcher sees the correct information for the location of the phone from which 911 is dialed.

In addition to requiring that an MLTS be capable of permitting a caller to dial 911 without any other digits or code, such as a prefix, the statute and the FCC’s implementing rules require a notification be sent with each 911 call. This notification must automatically be sent to a central location or to another person or organization regardless of location. The notification can be in the form of on-screen messages with audible alarms for security desk computers, text messages for smartphones, or an email for administrators. The form of notification used does not have to guarantee receipt, but it must be delivered where someone is likely to see or hear it.

At a minimum, the MLTS Notification must include:

• The fact that a 911 call has been made
• A valid callback number, unless it is technically infeasible to provide one
• Information about the caller’s location that the MLTS conveys to the public safety answering point when the call to 911 is made, unless it is technically infeasible to do so.

The callback number in the MLTS Notification does not have to be a Direct Inward Dialing number to the 911 caller’s extension if one is not available.

RAY BAUM’S Act

In addition to the direct dialing and notification requirements of Kari’s Law, the FCC has also created rules to improve the dispatchable location information associated with emergency calls from MLTS phone systems. In environments such as hotels, school campuses, warehouses, and multi-level office buildings, it can be difficult to find the exact location of a person calling 911. RAY BAUM’S Act was created to ensure faster and more accurate responses to 911 calls. Under RAY BAUM’S Act, “dispatchable location” data must be conveyed to emergency services for all 911 calls without further action required by the caller, regardless of the technology type.

The FCC noted that there were greater difficulties in providing location information for devices that were not used at a single fixed location, and adopted rules based on the distinction between “fixed” and “non-fixed” MLTS or VoIP devices. Fixed devices are those that connect to a single end point (e.g., a desk or office phone) and are not capable of being moved to another endpoint by the employee. Non-fixed devices are devices that the employee can move from one location to another. While non-fixed devices have greater flexibility in the type of location information provided, dispatchable location information is still the “gold standard” to which the FCC’s rules aspire.

Fixed MLTS
The FCC found that providing dispatchable location information was technically feasible for fixed MLTS devices. This phase went into effect January 6, 2021, and fixed MLTS must transmit the dispatchable location information associated with a fixed MLTS device to the PSAP, without further intervention by the user at the time they place the call.

Non-Fixed MLTS
For non-fixed MLTS, as of January 6, 2022, providers must either convey:

• • • Automated dispatchable location for 911 calls when technically feasible, or
    • Manually updated location information, or
    • Alternative location information, defined as location information (which may be coordinate-based) sufficient to identify the caller’s civic address and approximate in-building location. Additionally, alternative location information for large multi-story buildings should include the floor level and approximate location on the floor.

Remote MLTS
After January 6, 2022, MLTS devices operated outside of your business premises must provide the following when making a call to 911:

• • • Dispatchable location, if technically feasible, or
    • Manually updated dispatchable location, or
    • Enhanced location information. This information may be coordinate-based and should consist of the best available location that can be obtained from any available technology or combination of technologies.

Kari’s Law and RAY BAUM’S Act Compliance
Your business needs to have a complete safety protocol in place for its facilities. Complying with 911 regulations will help you to properly plan for the safety of your onsite and remote employees. Additionally, failure to bring your business to compliance can result in large fines up to $10,000 and additional penalties of up to $500 per day of noncompliance.

To verify your phone system is compliant you’ll need to find the administrative phone number for your location’s 911 call center, likely known as the public safety answering point (PSAP) and ask what steps you need to take to verify that your location is compliant.

You’ll need to be sure that the following information is displayed for the 911 operator should someone need to call for emergency help:

1. The name of your business
2. The address from which you are calling
3. The telephone number from which you are calling

This information needs to be verified for each outbound line in your building(s).

The requirements for Kari’s Law went into effect on February 16, 2020. The requirements for RAY BAUM’s Act are as follows:

• January 6, 2021
  • Fixed MLTS:
  • Fixed 2-way VoIP
  • Fixed Telephony
• January 6, 2022
  • Non-Fixed MLTS
  • Remote MLTS
  • Non-Fixed 2-way VoIP
  • Outbound-only VoIP

If your system is not able to reach 911 without dialing another number first, or if you’re not sure if your business telephone system complies with Kari’s Law and RAY BAUM’S Act, contact your local Ideacom Network telecom provider who can work with you to be sure all the necessary programming changes have been made to your system to bring you into compliance.