How Kari's Law and RAY BAUMS Act Affect CallTower Direct Routing and Operator Connect
Summary
A guide for CallTower customers using CallTower's solutions for Microsoft Teams.
Introduction
Teams telephone systems are now common in hotels, offices, schools, and other large buildings. They allow users to dial direct extensions and numbers within the same network, as well as external numbers. However, they also pose some challenges for emergency communications, especially when dialing 911. Two federal laws, Kari's Law and RAY BAUMS Act, aim to address these challenges and ensure that Teams users can access 911 services quickly and reliably. In this document, we will describe the main provisions and technical requirements of these two laws and how they affect Teams customers using CallTower's solutions for Microsoft Teams, namely Direct Routing and Operator Connect.
Kari Law
Kari's Law was enacted in 2018, after a tragic incident in 2013, when Kari Hunt Dunn was killed by her estranged husband in a hotel room in Texas. Her nine-year-old daughter tried to call 911 four times from the hotel phone, but could not reach the emergency services, because she did not know that she had to dial 9 first to get an outside line. Kari's Law requires that all MLTS allow users to dial 911 directly without having to dial any prefix or access code. It also requires that Teams notify a designated central location, such as a front desk or a security office, when a 911 call is made, so that on-site personnel can assist the emergency responders.
The technical requirements of Kari's Law are as follows:
- Teams must be configured to allow users to dial 911 directly, without any prefix, postfix, or trunk access code.
- Teams must provide a notification to a central location at the facility where the system is installed, or to another person or organization regardless of location, if the system is able to provide such notification without an improvement to the hardware or software of the system.
- The notification must include, at a minimum, the following information: the fact that a 911 call has been made, a valid callback number, and the information about the caller's location that the system conveys to the public safety answering point (PSAP).
- The notification must be initiated contemporaneously with the 911 call, and must be by a conspicuous means, such as audible, visual, or textual, that is reasonably certain to alert the designated person or organization.
For Teams Customers using CallTower's Direct Routing or Operator Connect solutions for Microsoft Teams, Kari's Law compliance can be achieved by following these steps:
- Ensure that Microsoft Teams and supports direct dialing of 911 without any prefix or access code, for Operator Connect this configuration is set by CallTower and is enabled by default for all customers. Including 933 for testing. Direct Routing customers may use the following guide to configure their tenant for 911 and 933:
- Configure Teams to send a notification of 911 calls to a designated Teams user or group, using Microsoft’s Emergency policy to configure notifications.
- Ensure that Teams provides accurate and up-to-date location information for each networked device, using teams Emergency Locations tab in the Teams Admin Center.
RAY BAUMS Act
RAY BAUMS Act was enacted in 2019, as part of the broader Pallone-Thune Telephone Robocall Abuse Criminal Enforcement and Deterrence (TRACED) Act. It is named after Ray Baum, a former Oregon legislator and Federal Communications Commission (FCC) staff member, who died of cancer in 2018. RAY BAUMS Act requires that all MLTS, as well as other types of voice services, provide accurate and dispatchable location information to the PSAP when a 911 call is made. Dispatchable location information means the validated street address of the calling party, and additional information such as suite, apartment, or similar information necessary to adequately identify the location of the calling party. The purpose of this requirement is to enable emergency responders to locate the caller quickly and efficiently, especially in complex buildings or campuses.
For Teams customers the technical requirements of RAY BAUMS Act are as follows:
- Teams must provide dispatchable location information to the PSAP with each 911 call, regardless of the technology platform used, unless it is technically infeasible or cost-prohibitive to do so.
- If dispatchable location information is not feasible or cost-effective, Teams must provide an alternative location information, such as coordinate-based or other non-dispatchable location information, or the best available location information that can be obtained from any available technology or combination of technologies at reasonable cost.
- Teams must also provide a callback number to the PSAP with each 911 call, if such number is technically feasible and provides a suitable method of contacting the user.
- The FCC may grant waivers, exemptions, or extensions of time to comply with these requirements, based on the public interest, technical feasibility, or cost-effectiveness.
For Teams Customers using CallTower's Direct Routing or Operator Connect solutions, RAY BAUMS Act compliance can be achieved by following these steps:
- Ensure that Teams provides dispatchable location information for each user or device, using the Emergency Locations tab in the Teams Admin Center.
- If dispatchable location information is not available or feasible, provide an alternative location information, such as the civic address, the geolocation coordinates, or the network address of the user or device, using the Emergency Locations tab in the Teams Admin Center.
- Ensure that Teams routes 911 calls to CallTower's emergency services provider, which will deliver the calls and the location information to the appropriate PSAPs.
Conclusion
Kari's Law and RAY BAUMS Act are two federal laws that aim to improve the access and effectiveness of 911 services for Teams users. They impose certain technical requirements on Teams Customers, such as allowing direct dialing of 911, providing notifications of 911 calls, and conveying accurate and dispatchable location information to the PSAP. These requirements are intended to enhance the safety and security of Teams users, and to facilitate the timely and accurate response of emergency personnel. Teams Customers using CallTower's Direct Routing or Operator Connect solutions for Microsoft Teams should be aware of these requirements and comply with them accordingly or seek waivers or exemptions from the FCC if necessary.