Kari’s Law and The Ray Baum Act
There has been 2 pieces of federal legislation passed recently that affect your phone system and phone service. As a technology industry leader, ComRes has prepared the following information to the best of our understanding on what you should do to be compliant with these new regulations.
Please note, we are not attorneys and are not attempting to give legal advice. This information is to help make you aware of regulations regarding our industry and your phone system/service. We encourage you to seek legal advice from your attorney if you have further questions.
Kari’s Law
What is Kari’s Law?
This is legislation that was passed regarding e911 emergency services for anybody that has a multi-line telephone system (MLTS).
What does Kari’s Law require?
There are 2 key provisions of Kari’s Law:
Calling 911 without an access code – Kari’s Law prohibits the requirement for a prefix or access code such as “9” or “8” when calling 911.
On-Site Notifications – When a user calls, a notification must be sent to on-site personnel, alerting them to the 911 call via phone calls, visual alerts on a monitor, audible alarms, text messages, and/or emails.
When am I required to be compliant?
There are 2 critical dates:
New systems – any new system/service installed on or after February 16, 2020 must be compliant with this law.
Existing systems/service – all existing systems/services have until January 6, 2021 to be compliant.
What are the costs of non-compliance?
Even though this is federal law, the enforcement for this falls on the state where your system/service are. Each state, and possibly local governments will be responsible for ensuring compliance and issuing fines for non-compliance.
Important note – just because you are not required at this time to be compliant does not necessarily absolve you from potential liability or bad publicity resulting from non-compliance.
The Ray Baum Act
What is the Ray Baum Act?
The Ray Baum Act is a large bill regarding communications, access and funding. Among other things, section 506 specifies that 911 calls from an MLTS must provide a ‘dispatchable location’ to e911 services. For larger buildings or businesses, this means that in addition to your street address, you must also provide relevant dispatchable location information such as the building, floor, room number, suite number, etc.
It references 2 types of service. One is ‘Fixed’ which is for systems or phones in fixed locations. The second is for ‘Non-Fixed’ which is for mobile type phones/softphones. Non-fixed affects users who may move IP phones between locations, login from different locations (e.g. Hot Desk), or use soft phones on PC’s or mobile phones.
When am I required to be compliant?
Fixed systems/service – January 6, 2021
Non-fixed systems/service – January 6, 2022
Important note – just because you are not required at this time to be compliant does not necessarily absolve you from potential liability or bad publicity resulting from non-compliance. However, at this time, ComRes has not been able to ascertain how to be 100% compliant with Section 506 of this Act. ComRes has spoken with several phone system manufacturers, service providers, state/local regulatory officials and industry leaders. As of February, 2020, there are steps missing in the process on how to implement and be compliant with Section 506 of this act. Additionally, there will most likely be customer equipment that may need to be installed/upgraded to be able to be compliant with the Non-Fixed systems/services for users who move between locations or are mobile.
What are the costs of non-compliance?
Even though this is federal law, the enforcement for this falls on the state where your system/service are. Each state, and possibly local governments will be responsible for ensuring compliance and issuing fines for non-compliance.
Compliance and Next Steps
Kari’s Law Compliance
ComRes is already assisting customers to be compliant with the main 2 elements of this regulation.
Managed Services and ComRes CloudTalk VoIP customers – you don’t have to do anything. ComRes is already working in the background to make all of our Managed Voice Services (MVS) and ComRes CloudTalk VoIP customers compliant. There is no charge for this for MVS or CloudTalk VoIP customers.
Blocks of Hours and Time & Materials (T&M) customers – All other customers such as Blocks of Hours or T&M customers can schedule with ComRes for compliance.
Ray Baum Act (Section 506) Compliance
At this time, ComRes is still working on what is required to be compliance with this section of the law. We are currently testing this with systems at ComRes and seeking further guidance from carriers, manufacturers, and regulatory officials. Once we have a complete understanding of what is required, we will reach back out to our customers and discuss what is needed.
Contacting ComRes
ComRes strives to be your technology solutions expert. If you have any questions about these regulations, how to be compliant or what to do next, please contact your ComRes representative at:
Phone: 954-462-9600 (toll free 877-379-9600)
Email: Service@ComResUSA.com
