This week marks the inception of two new federal laws that any business or entity that uses a Multi-line Telephone System. These two laws are Kari’s Law and the Ray Baum Act. The purpose of this announcement is to inform you of the new laws, understand your requirements, and the steps you can take to make sure you comply.

• Kari’s Law

  Kari’s Law Act of 2017 (codified at 47 U.S.C § 623) or “Kari’s Law” was introduced to ensure that in case of an emergency, callers have direct-dial access to emergency 911 services from all devices. It also makes it easier for first responders to locate the emergency when the call is placed from a business phone number. Noncompliance with the law could lead to a fine of up to $10,000 and additional penalties of up to $500 per day of noncompliance. In order to be compliant, what does Kari’s Law require?

  • Callers must be able to dial 911 without the need to enter any prefix or postfix digits, i.e. (no dial “9” first)
  • Phone system must automatically send notifications of the 911 caller location to designated personnel

• Ray Baum’s Act

  This new law, that builds on Kari’s Law, was passed in March 2018 by the US House of Representative and it is estimated it will go into effect in late 2020. The Act requires that “Dispatchable Location Information” be conveyed by the phone system to the Public Safety Answering Point (PSAP) when 911 is dialed.

  Dispatchable Location Information is defined as more specific information than just a street address. For hotels it could include conveying information such as room number, floor number, meeting room ID, pool, exercise room, etc.

  The notification must be sent to the central location/person in the business at the same time as the call is placed, without delaying that the call goes through to the 911 PSAP.

Businesses and Entities Must Comply

While there is some ambiguity in both laws, the primary requirements listed above leave little question businesses will be required to take steps to insure employees and visitors can directly dial 911 and a notification of the call be sent to a central location/person at the facility providing immediately awareness of the call.

Many states have their own 911 calling requirements and neither law supersedes these state laws, however, each business must meet the requirements of Kari’s Law and Ray Baum’s Act at a minimum.

How Do I Meet the New Requirements?

The good news is many of the systems installed by ATS can be programmed to meet compliancy, if they are not already. Systems programmed to dial “9” first and then the phone number may require a change in programming to allow a direct call to 911. Sending the notification to a designated recipient within the facility is a more enhanced feature older digital telephone systems may not be able to accommodate. Both pieces are required to meet compliancy.

We recommend you contact your ATS account manager (or ATS Service if you do not know your account manager) especially if your system if over 5 years old, to review your current design with our team so we can either schedule to re-program your system or further discuss alternative options.

It is our understanding that systems in place prior to February 16, 2020 may be “grandfathered” until the system is upgraded or replaced. There is still some ambiguity regarding what constitutes a “system upgrade” triggering the requirement that the system must comply with the new laws. We expect the FCC will clarify or make a ruling on this at some point soon. To the best of our understanding some older systems which cannot easily be re-programmed have some time to make the necessary changes:

• Fixed Phones: Physical phones that are static in an environment. These phones must meet these requirements January 6th, 2021.
• Non-Fixed: Softphones or physical phones that move (IP Phones) in a business environment. These phones must meet these requirements by January 6th, 2022.
• Remote: Off-premise 911 calls such as remote workers or people working from home. These phones must meet requirements by January 6th, 2022.

Penalties and Who Must Comply

Because it is the law there are consequences if corrective action is not taken and if you are found non-compliant.

• Penalties: “$10,000 fine and $500 per day till it’s fixed”

Summary

A horrible experience was made worse because a child could not easily dial 911 from a hotel (business) phone when emergency services were needed which has led to new laws in order to allow people to dial for emergency help without any restrictions. Many business or entity phone systems may need to be re-programmed and/or upgraded or replaced to meet the requirements of these new laws. Older systems that cannot be altered may have as a grace period to make accommodations to meet requirements. Failure to address these new laws can result in penalties and fines.

ATS is sharing these laws so you are aware of the responsibility of your organization and is ready to help you identify what is needed and how to best implement the necessary changes to meet the compliancy requirements. We encourage you to contact your ATS account Manager or our ATS Service Center by calling (800) 995-4287, Press 1 for service. Or you can email us at Service@teamATS.com and use the Subject Line Kari’s Law to start the process of meeting the new legal requirements.

Additional Information and Resources:

This article is intended to provide you with general information regarding the new 911 laws and is not intended to provide specific legal or business advice. If you have any questions about new laws or you need legal advice, we recommend that you contact your attorney.