Frank Melville, CEO and President of Phonesuite

CEO Frank Melville Answers Your Questions About Kari’s Law and RAY BAUM’S Act

We’ve talked before about two new pieces of legislation that affect the way hotels and other multi-line telephone systems (MLTS) handle emergency calls: Kari’s Law and RAY BAUM’S Act. Recently, our CEO and President Frank Melville sat down with several clients and installers to go over the final details of what these new laws require and how hotels should prepare.

What Do These Laws Include?

Kari’s Law is named after a woman who died in a hotel room when her young daughter couldn’t dial 911 because she couldn’t reach an outside line. The new law requires that every phone in an MLTS be able to reach an outside line without a prefix. It also requires “onsite notification,” alerting the front desk any time an emergency call is placed from within the network.

RAY BAUM’S Act is a very large bill covering many communications-related areas, but the relevant section for our purposes is Section 506, which requires that all 911 calls from an MLTS come with “dispatchable locations” — not just the street address or building, but the exact floor and room. We’ve talked to the FCC about what exactly a dispatchable location entails and they essentially told us that fire or paramedics need to know “which door to kick down.” For hotel purposes, this is generally going to mean a room number or identifier like the restaurant, gym, conference room A, etc.

When Do These Laws Take Effect?

Kari’s law took effect in February of 2020, but most MLTS providers made the necessary compliance changes nearly a decade ago, when the original incident took place. Phonesuite systems have been in compliance with Kari’s Law for several years now. 

RAY BAUM’S Act takes effect in two parts. The first is for what’s called “fixed-line phones,” which essentially means phones that are plugged into a wall. That took effect in January of 2021. The second part, for non-fixed-line phones, won’t take effect until January 6 of 2022, so providers have some time to implement new solutions.

Who Does The Law Concern?

It’s important to note that these laws only apply to phone systems installed or “significantly upgraded” after the effective dates. The FCC has not been clear about what a “significant” upgrade entails, but it’s a safe bet that if you perform an upgrade that could make the new system compliant, you should. Something as simple as buying new VoIP handsets likely would not be considered significant.

How Do I Make My System Compliant?

Any phone system installed new will need to comply with both laws. An MLTS can be pre-configured on installation to dial 911 directly and report the call to the central manager in compliance with Kari’s Law, but the dispatchable location is slightly more complicated.

Right now, the best solution we’ve found is to set up a unique DID for every phone in the system that reports back to the local PSAP for emergency calls. This configuration process will be unique for every hotel, so it’ll be up to our resellers and installers to configure your system when it goes in.

The carrier also plays a role. Whichever carrier your hotel uses for phone calls needs to be compliant with RAY BAUM’S Act, meaning it’s capable of transmitting dispatchable location data along with the call itself. We’re working on new technology that will make this process of registering dispatchable locations much easier and more efficient, but it’s not ready to be deployed yet and will only work with certain carriers.

When you register your phone system with the local carrier, you’ll need to register each phone with the correct dispatchable location description. Most carriers allow 60 characters, which should be enough for a street address and room number, but it’s the responsibility of the hotel owner or manager to ensure that all DID information is properly filled out for each phone’s location.

What If I Move My Phones?

If you take a work phone home and use it there, it’s considered a non-fixed line. The tricky issue is that by this definition, any SIP phone can be considered a non-fixed line because it can be moved to any location with an internet connection and still ring on the same number. We don’t want you calling 911 on the work phone you brought home and sending dispatchers to the hotel, but we also don’t want to have to re-register your location every time you leave the building.

Right now, hoteliers have the ultimate responsibility to ensure that locations are properly registered to the right location, but it’s an inelegant answer to a question that the legislation doesn’t properly address.

What About Analog Lines?

It’s difficult to make analog lines compatible with these new laws, but not impossible. If you’re willing to register every individual trunk as a new location and possibly physically alter the wiring to reach an outside line directly, you can still make an analog system work. We highly recommend switching to a PBX to stay compliant with this and any future legislation.

Keep Paying Attention

The unfortunate truth is that we don’t know exactly how this will play out. We’re working on several solutions to make the switch easier and add dispatchable locations for non-fixed lines, but we don’t know exactly what that will look like.

We also don’t know what liability will look like if someone has an emergency in a hotel room. Will responsibility lie with the manufacturer of the phone system, the installer, or the hotel? We asked the FCC and they told us that we’ll have to wait until lawsuits establish legal precedent to answer these questions, which is a very unsatisfying answer for hoteliers who want to be careful about their liability.

These changes are very new, so it’s only natural that they have significant wrinkles that will be ironed out over time. In the meantime, Phonesuite will do everything we can to help our current and future customers stay compliant with all relevant laws and regulations around their phone systems. If you have any questions, feel free to contact us.


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