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E911, Kari's Law & RAY BAUM'S Act

Two federal laws impose different obligations on multi-line telephone systems. Most organizations have implemented one of them, partly, and assume that covers both.

In August 2019 the FCC adopted rules implementing two federal laws that strengthen emergency calling from multi-line telephone systems: Kari's Law and Section 506 of RAY BAUM'S Act. They are frequently spoken about as one requirement. They are not — they ask for different things, and an estate can satisfy one while failing the other.

Kari's Law: reach 911, and tell someone

Kari's Law is named for Kari Hunt, who was killed in a motel room in Marshall, Texas in 2013. Her nine-year-old daughter tried to call 911 four times from the room phone. None of the calls connected, because she did not know the motel's phone system required dialing "9" for an outside line first.

The law imposes two obligations on organizations operating an MLTS:

The notification requirement is the one that gets missed Direct dialing is a dial-plan change and it is usually done. Notification is an architecture question — who is alerted, through what channel, and does it reach a human at 3am on a Sunday? An alert routed to an unmonitored mailbox is a compliance record with no operational value.

RAY BAUM'S Act: say where the caller is

Section 506 of RAY BAUM'S Act requires that 911 calls convey a dispatchable location. The FCC defines this as a location delivered to the Public Safety Answering Point with a 911 call, consisting of the validated street address of the calling party plus additional information such as suite, apartment, or similar detail.

In practice, the obligation is to supply:

On a campus, the street address alone is close to useless. "1 Hospital Way" tells responders nothing when there are nine buildings and eleven floors. The additional detail is the whole point of the requirement.

Scope and compliance dates

The dispatchable location rules apply to MLTS manufactured, imported, offered for first sale or lease, first sold or leased, or installed after 16 February 2020. Compliance deadlines of 6 January 2021 and 6 January 2022 apply depending on the nature of the device from which the MLTS 911 call originates.

Both dates are long past. The practical question in 2026 is not whether the deadline has arrived — it is whether your estate actually complies, and whether you could demonstrate it.

The three device categories

This is where most implementations fall short, because the obligation is defined differently for each category and organizations tend to solve only the first.

Fig. 1 — three device classes, three obligations and the gap most estates have
On-premises, fixed desk phone, known port Building · floor · room automated, from switch port On-premises, nomadic Wi-Fi handset, laptop AP or subnet derived where technically feasible Off-premises home-working agent HQ address unless deliberately designed PSAP dispatches to what it actually receives The clay path sends responders to your head office while the caller is three states away. It is the most common gap we find.
Kari's Law and RAY BAUM'S Act ask for different things, and the location duty is defined per device class. Solving it for desk phones — which most estates have done — leaves the remote-agent population entirely uncovered.
CategoryExampleObligation
On-premises, fixed Desk phone in a known office Must provide automated dispatchable location with the 911 call. The system determines it; the user is not asked.
On-premises, non-fixed Softphone on a laptop, wireless handset moving between floors Automated dispatchable location where technically feasible; otherwise alternative location information sufficient to route and dispatch.
Off-premises Home worker, agent on a softphone anywhere Dispatchable location where technically feasible; otherwise alternative location, which may be user-provided and must be maintainable and updatable.

Compliance applies to any facility using an MLTS — corporate offices, hotels, hospitals, college campuses, and similar.

The remote agent problem Distributed contact centers created a large population of off-premises endpoints attached to an enterprise phone system. An agent working from home who dials 911 from a softphone registered to the corporate platform will, without deliberate design, present the corporate headquarters address. That sends responders to the wrong city. This is the single most common gap we find.

How dispatchable location is actually determined

There is no single mechanism. Most estates need several, layered by device category.

MethodWorks forLimitations
Switch port / patch panel mappingFixed desk phones on wired ethernetOnly as accurate as the cabling records, which decay. Needs a maintenance process, not a one-off survey.
LLDP-MED / network element discoveryWired IP phonesRequires switch support and consistent configuration across the estate.
Wireless access point associationWi-Fi handsets and softphones on siteAP-to-location mapping must be maintained; coverage overlap can put a device on the wrong floor.
Subnet / VLAN mappingCoarse building-level locationToo coarse on its own for a large building. Useful as a fallback layer.
User-declared locationOff-premises and remote workersDepends on users updating it. Needs prompting on network change and periodic reconfirmation.
Location service provider integrationAll categoriesUsually the practical answer at scale. Verify what your platform natively supports before assuming.

An assessment checklist

  1. Census every endpoint by category. Fixed, nomadic on-site, off-premises. Include the systems people forgot were still connected.
  2. Test direct dialing from every system. Actually dial — using a test number or in coordination with your PSAP, never a live 911 call for testing. Legacy PBXs hiding in a corner are exactly where a prefix requirement survives.
  3. Verify what the PSAP receives, not what your platform believes it sent. These differ more often than expected.
  4. Trace the notification path end to end. Who is alerted, by what channel, and confirm a human receives it out of hours.
  5. Define the location maintenance process. Moves, adds and changes degrade location accuracy continuously. Without a process it is accurate on day one and wrong within a year.
  6. Document the evidence. If you are asked to demonstrate compliance, what would you produce?

Where this intersects with migration

Every telephony migration touches 911, and it is routinely treated as a cutover task rather than a workstream. Two specific risks:

Related reading

Remote agents presenting headquarters as their location is the gap we find most often.

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