How New FCC Regulations May Affect Your VoIP System

The FCC is already requiring all new US phone systems to meet their Enhanced 911 (E911) compliance regulations, and coming up in January, the regulations expand to many existing phone systems.

What is Enhanced 911 (E911)?

In 2018, Congress enacted legislation concerning 911 calling and reporting for all multiline telephone systems (MLTS), including Voice over Internet Protocol (VoIP) phone systems. The legislation, known as Kari’s Law and the Ray Baum Act, were adopted by the FCC in 2019 to enhance our national emergency calling services.

FCC rules dating back to 1999 already require all private companies, public agencies and non-profit organizations to provide 911 access on every phone for emergency dispatch of 911 services for life-or-death situations. These new E911 rules were created to provide accurate location information and a callback number to local public-safety answering points (PSAPs) as an added safety precaution during emergency situations.

Traditional 911 sends calls to the PSAP or 911 dispatcher to alert emergency services like the police or fire department based on the installation address of the local carrier circuit. The challenge of providing 911 services with VoIP solutions is that an IP caller could be using a public or private IP network to use a carrier phone line installed in another location, meaning the address of the phone circuit is no longer a reliable indicator of where the emergency is. With E911, calls routed to the PSAP include additional information to help the emergency operators ensure that emergency services are sent to the correct location.

Kari’s Law and the Ray Baum Act

Portions of the FCC’s new rules based on the Ray Baum Act and Kari’s Law went into effect during February of this year, with more deadlines coming in January 2021 and January 2022. These rules detail specific mandates that businesses must be aware of and act upon in order to be considered compliant with these new laws.

Kari’s Law requires MLTS users to enable direct dialing of 911 without prefix or other digits required. Kari’s Law also requires them to notify appropriate personnel onsite that a caller dialed 911, and include the details of the dispatchable location to decrease response time when emergency services arrive onsite.

The Ray Baum Act requires MLTS users to provide the PSAP a “dispatchable location”, defined as “… a street address, but should also include more granular information such as building number, floor, suite, room, or other available relevant location information that can best assist first responders in an emergency” for all 911 calls.

What new E911 compliance laws mean for your business

Together, these laws mean that all businesses and organizations will need to ensure that:

  • All facilities with voice communication access to the public switched telephone network (PSTN) provide E911 service.
  • Callers can reach 911 without dialing a prefix (such as ‘9’) to reach an outside line.
  • All 911 calls simultaneously notify designated personnel in the form of a phone call, email, SMS/text message, or conspicuous on-screen message.
  • All 911 calls include a callback number, name and location to be routed directly to the PSAP.
  • Communications equipment provides a “dispatchable location” to the PSAP.
  • In instances where 911 service limitations exist, labels are placed on VoIP-enabled devices notifying potential callers of the limitation.

The only exception provided in the legislation concerns systems installed, sold or leased on or before February 16, 2020 that do not have the ability to provide one or more of these features, which may be exempt from that requirement. While it’s unlikely that many MLTS systems produced for the last several years would be unable to meet these requirements and qualify for an exception, if you feel your organization may be exempt, you should be aware of the activities that may change your exempt status.

The laws go on to explain that any exemption will only remain until the operator of the MLTS makes a “significant change” to the system. Industry analysts interpret “significant change” to mean any system or software upgrade to the MLTS, which would then make the system or operator subject to compliance.

When must your business be compliant with E911 laws?

  • The direct dialing and onsite notification rules derived from Kari’s law are already in effect for any phone system installed, sold or leased after February 16, 2020, on premises or in the cloud.
  • The requirement to provide the PSAP a dispatchable location derived from the Ray Baum Act goes into effect:
    • For all “fixed” calling devices (such as a wired or landline phone) by January 5, 2021.
    • For all “non-fixed” calling devices (such as either a wireless, cellular or software-based phone) by January 5, 2022.

How can Sirius help your organization become compliant?

As an experienced E911 solution provider, Sirius can help put together a plan for your organization whether you are just starting out or are ready to implement specific solutions. We offer several technologies and professional services that can help bring all of your IP telephony services, digital collaboration, and unified communications solutions up to code, including:

  • Consultations and assessments
  • Caller location tracking
  • Routing calls to correct PSAPs
  • Providing location information to the PSAP
  • Notifying key personnel in an emergency

If you have questions about how Sirius can help your organization meet these new compliance requirements, be sure to contact us or call 800-460-1237 for more information.

By |2020-12-18T16:04:06-06:00December 14th, 2020|Blog|Comments Off on How New FCC Regulations May Affect Your VoIP System

About the Author:

Michael Dempsey is an Infrastructure Solutions Technical Architect for Sirius.