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Are You Compliant with FCC 911 Regulations?

No call is more important than a call to 911. We rely on 911 when seconds matter most and lives are on the line. However, multi-line phone systems (MLTS) present challenges for ensuring 911 calls are routed accurately, and emergency responders can locate the caller whether they are in the office, at a remote location, or on the road. Additionally, MLTS dialing requirements for outgoing calls and confusing building layouts can create barriers that prevent emergency responders from quickly getting to people in need. In August 2019, the Federal Communications Commission adopted two pieces of legislation designed to remove the barriers and make it easier to access emergency services, Kari’s Law and Section 506 of RAY BAUM’S Act.

Kari’s Law

Kari’s Law honors Kari Hunt, who was killed by her estranged husband in a motel room as her 9-year-old daughter tried to call 911 for help. None of the calls went through because the motel’s phone system required dialing “9” for an outbound line before dialing 911. The statute requires pre-configuring phone systems to support direct dialing of 911 without dialing any prefix or access code, such as the number 9.

Additionally, Kari’s Law requires MLTS phone systems to automatically notify on-site security personnel and administrators that someone in the building has dialed 911. The notification must include an alert that a 911 call was placed and include a callback number and information about the caller’s location.



Many legacy MLTS systems only provided 911 emergency dispatchers with the number and address of the system’s outgoing trunk and not the caller’s actual location. RAY BAUM’S Act ensures first responders have the information they need to find the person who dialed 911 quickly. It requires automatically conveying precise physical location information to the dispatch center when 911 is dialed. Compliance with RAY BAUM’S act can be a bit tricky for organizations using MLTS with multiple buildings or multi-story buildings as the location must include the street address, floor number, room number, or similar information necessary for emergency responders to locate the calling party quickly.


911 Compliance

Kari’s Law and RAY BAUM’S Act have been in effect since early this year. Under the statutes, owners/operators of MLTS have unique requirements for Enhanced 911 (E911):

  • Offering 911 service is a mandatory requirement. Organizations cannot “opt-out” of providing emergency calling capabilities.
  • All 911 calls must be seamlessly routed to the appropriate designated public safety answering point (PSAP) and include a callback number and accurate location information.
  • When a 911 call is initiated, the system must notify a central location on-site or off-site where someone is likely to see or hear the notification. For example, a conspicuous on-screen message with an audible alarm for security desk computers using a client application, text messages for smartphones, and email for administrators.


Who is Affected?

Kari’s Law and RAY BAUM’S Act impact organizations and enterprises of any size using an MLTS, Including:

  • Companies with large facilities or offices in multiple locations
  • K-12 schools, universities, and college campuses
  • Hospitals and clinics
  • Hotels and resort properties
  • Retail facilities

Keep in mind that 911 calling for remote, small office/home office (SOHO), mobile, and hybrid workers must also be addressed. All users with company-managed phone numbers are also required to be compliant.


Next Steps

Carrier-level E911 service is one component of FCC compliance but not enough on its own. We can help you assess your current situation and make concrete recommendations for navigating the complex requirements of Kari’s Law, RAY BAUM’s Act, and local 911 regulations.

Schedule a E911 Readiness Assessment today.

With decades of industry experience, Cerium experts specialize in eliminating 911 pain points and simplifying E911 administration. FCC requirements are a key consideration in our solution designs. Connect with Cerium to learn more about 911 solutions for keeping your users safe while complying with FCC regulations.

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