When someone calls 911 from a hospital, school, hotel or office campus, every step matters. Can they reach emergency services directly? Will the right people know a call was placed? Can responders find the caller within a large building?
Kari’s Law and RAY BAUM’S Act address these concerns from different angles, which is why they’re often discussed together. Kari’s Law establishes requirements for direct 911 dialing and notification, while the FCC’s rules implementing Section 506 of RAY BAUM’S Act focus on delivering accurate caller-location information to emergency services.
The federal multi-line telephone system (MLTS) requirements discussed here apply across industries to covered systems and assign responsibilities to the businesses and individuals that manufacture, import, sell, lease, install, manage or operate them.
Although these requirements have been in effect for years, maintaining compliance remains an ongoing responsibility. Whether you’re reviewing existing systems, planning facility changes or evaluating new safety technology, understanding these laws can help you identify gaps and ensure your emergency-calling procedures continue to meet your organization’s needs.
Kari’s Law establishes emergency access requirements for multi-line telephone systems (MLTS), including many business PBX and VoIP systems used in healthcare, education, hospitality, government and corporate environments. Effective February 16, 2020, the federal requirements apply to covered systems manufactured, imported, offered for first sale or lease, first sold or leased, or installed after that date.
Under the FCC’s rules, covered systems must support two essential functions:
Users must be able to dial 911 directly without entering an outside-line digit, such as 9, or another access code. This removes an unnecessary barrier that could prevent someone from reaching emergency services.
The system must also notify a designated on-site or off-site recipient when it can be configured to do so without a hardware or software improvement. The notification must reach a location where someone is likely to see or hear it without delaying the emergency call. When technically feasible, it must begin at the same time as the call.
The notification must identify that a 911 call occurred and include a valid callback number and the caller-location information conveyed to the 911 center, except where providing either detail is technically infeasible.
Beyond meeting the technical requirements, organizations should ensure that designated personnel understand how to respond when a notification arrives. This includes knowing how to help emergency responders access the facility and locate the person requesting help.
Review the FCC’s direct-dialing and notification requirements in 47 CFR § 9.16.
Enacted in 2018, RAY BAUM’S Act is a broad federal communications law addressing issues such as telecommunications infrastructure, broadband access, regulatory oversight and public safety. Section 506 of the Act focuses on emergency calling and the importance of providing enough location information for responders to find someone who needs help, directing the Federal Communications Commission (FCC) to consider rules that improve the location information delivered with 911 calls.
For example, on a hospital campus or in a large office complex, responders may need to know which building, floor or room the caller is in. The FCC's resulting rules address this through dispatchable location, which combines a validated street address with the additional information necessary to adequately identify the caller's location, such as a building name or number, floor, suite or room number.
For covered multi-line telephone systems (MLTS), these requirements vary based on the type of device and where it's used:
Since January 6, 2021, covered fixed on-site phones must automatically provide dispatchable location information with 911 calls, helping emergency responders identify where assistance is needed.
Since January 6, 2022, covered devices that can move between locations within a facility must provide automated dispatchable location when technically feasible. Otherwise, the rules permit manually updated dispatchable location or qualifying alternative location information.
Also effective January 6, 2022, covered devices used away from the organization’s premises must provide automated dispatchable location when technically feasible. Otherwise, they must provide manually updated dispatchable location or qualifying enhanced location information.
Organizations should verify that the required location information reaches the public safety answering point (PSAP), the emergency communications center receiving the 911 call. A room number displayed on an internal security dashboard does not necessarily mean that information was transmitted to emergency services.
Working with telephone and E911 providers to validate location delivery, particularly after changes to phone configurations, network infrastructure or facility layouts, can help organizations maintain accurate emergency-calling information.
Review the FCC’s dispatchable-location requirements in 47 CFR § 9.16.
Maintaining compliance means regularly verifying that your emergency-calling systems work as intended, particularly after changes to your facilities, technology or staffing arrangements. The following checklist can help IT, facilities, security and compliance teams review their systems and identify areas requiring attention.
Inventory your systems. Account for desk phones, softphones, shared spaces and remote users across your organization.
Verify direct dialing. Confirm that covered devices can reach 911 without an outside-line prefix or additional access code.
Confirm notification delivery. Verify that 911 calls reach emergency services and, where required, trigger a separate notification to a designated on-site location or off-site recipient.
Check timing. Confirm that notifications do not delay the 911 call and begin at the same time when technically feasible.
Check visibility. Verify that notifications reach a location where someone is likely to see or hear them.
Reduce reliance on a single notification channel. 911Cellular recommends using multiple channels, such as desktop and mobile alerts, so designated personnel can receive notifications whether at their desks or moving through the facility.
Identify the call. Confirm that notifications clearly indicate a 911 call has occurred.
Include callback information. Verify that notifications contain a valid callback number unless technically infeasible.
Include caller location. Confirm that notifications contain the location information conveyed to the 911 center unless technically infeasible.
Verify caller-location accuracy and delivery. Confirm that the 911 center receives accurate location information reflecting current phone assignments and applicable building, floor or room details.
Review responder wayfinding. Ensure that someone unfamiliar with your facility can locate the caller using the information provided and facility signage.
Review response coverage. Identify who monitors notifications during regular operations and after hours.
Clarify responder assistance. Identify who helps arriving emergency responders access the facility and locate the caller.
Coordinate testing. Arrange controlled testing with your telephone and E911 providers and local 911 center. Contact the center through its non-emergency number and follow approved procedures.
Assign system ownership. Establish responsibility for maintaining configurations, coordinating reviews and correcting issues.
Document findings. Keep records of testing, system changes, corrective actions and outstanding issues.
These checks can help organizations identify potential gaps in their emergency-calling capabilities while strengthening the procedures that support an effective response.
Even with a properly configured phone system, employees may not always have a phone within reach during an emergency. A nurse moving between patient rooms, a teacher supervising students outdoors or a hotel employee working alone may need another way to request assistance.
Your review may also reveal gaps in how emergency notifications reach people or how response teams coordinate. Some can be resolved through system updates, clearer procedures or training. Others may present opportunities to replace outdated tools or consolidate disconnected safety systems.
Alongside a properly configured telephone and E911 environment, the 911Cellular Safety Platform brings staff panic button alerting, mass notification, incident management and reporting together in one system. Wearable, computer, mobile, VoIP and wall-mounted panic buttons provide different ways to request help.
The platform can connect with compatible telephone and E911 services to support emergency-calling workflows. Depending on the integration, 911Cellular can help notify designated personnel, provide location context and initiate alerts to emergency services where supported. These capabilities can support an organization's compliance efforts, but meeting Kari’s Law and RAY BAUM’S Act requirements depends on validating that covered 911 calls trigger the required notifications and convey the appropriate dispatchable-location information to the 911 center.
Beyond these requirements, the platform can provide dispatchers with additional incident context through connected security camera feeds and, during supported alerts, audio or video streams from compatible devices. Authorized dispatchers can take ownership, add notes and document resolutions through a shared incident view. Configurable workflows can also notify staff, students and others who need to take protective action through multiple channels, while activating lockdown controls, strobes and sirens through supported integrations.
Kari’s Law and RAY BAUM’S Act establish essential safeguards for emergency calling: direct 911 access, required notifications and accurate caller-location information. Maintaining these capabilities requires ongoing attention as your facilities, technology and staffing change.
But compliance is only part of emergency readiness. People also need accessible ways to request help, and response teams need the information and coordination to act effectively. If your review reveals gaps, reach out to 911Cellular to explore how we can help strengthen your organization’s emergency response.
This article provides general information about federal emergency-calling requirements and is not legal advice or a certification of compliance. Additional state or local requirements may apply. Consult qualified counsel regarding legal obligations and verify system capabilities with your telephone, E911 and safety technology providers.