Kari's Law and RAY BAUM's Act: the 911 rules for business phone systems

In 2013, a 9-year-old girl in a Texas motel room tried four times to call 911 while her mother was being attacked. The calls never connected, because the motel’s phone system required dialing 9 first for an outside line. Her mother, Kari Hunt, was killed.

That tragedy led to two federal laws that now govern how 911 works on business phone systems. If you manage or install a multi-line phone system (the FCC calls them MLTS, the kind found in offices, schools, hotels, and government buildings), these rules may apply to you.

Kari’s Law: direct dialing and notification

Under the FCC’s rules, an MLTS covered by Kari’s Law must:

• Let anyone dial 911 directly, without dialing 9 or any other prefix first.
• Notify someone on site when a 911 call is made, such as a front desk, security office, or designated person, so help can be met at the door. The notification can go to an on-site or remote location where someone is likely to see or hear it.

Which systems it covers: Kari’s Law applies to phone systems manufactured, imported, offered for sale or lease, first sold or leased, or installed after February 16, 2020. Systems in place on or before that date are exempt, but anything installed or replaced since then is covered.

Who’s responsible: manufacturers and sellers must ship systems ready for direct 911 dialing, and whoever installs, manages, or operates the system must make sure it’s configured that way. The notification requirement applies when the system can do it without new hardware or software.

RAY BAUM’s Act: dispatchable location

RAY BAUM’s Act requires that a 911 call deliver a dispatchable location: the street address plus details like the floor, room, or suite, so responders know where to go. The FCC set these compliance dates for phone systems:

• Fixed phones on the premises (desk phones): automated dispatchable location by January 6, 2021
• Non-fixed phones on the premises (phones that move around the building): automated location by January 6, 2022 when technically feasible, otherwise based on manual updates or alternative location information
• Off-premises devices (like softphones used at home): the same January 6, 2022 date, with the same fallback when automated location isn’t feasible

How to check your system

1. Pick up a desk phone and look at the dial plan. Can someone dial 911 without a prefix? If your system uses 9 for an outside line, confirm that dialing 911 (and 9-911) both reach emergency services. Coordinate any test call with your local 911 center first; never place a test call without warning them.
2. Check notification. Does a 911 call trigger an alert to the front desk, an email, or a notification to a designated person? Most modern systems can do this, but it has to be set up.
3. Check location settings. Most business phone systems have a place to define emergency locations (often called E911 locations) and assign them to phones or extensions. If that section is empty, 911 calls may carry only the main billing address, or no useful location at all.
4. Talk to your phone provider or installer. They should be able to confirm how your system handles 911 and what location information is sent.

This article is general information, not legal advice. For your specific obligations, check the FCC’s guidance and talk to your phone provider or counsel.

Sources

• Kari’s Law and RAY BAUM’s Act (FCC): the background of Kari’s Law, direct dialing and notification requirements, and the February 16, 2020 effective date
• FCC announces compliance dates for new E911 rules (Wiley Rein LLP): which systems are covered and the dispatchable location compliance dates
• FCC update on Kari’s Law and RAY BAUM’s Act (FCC Public Safety and Homeland Security Bureau, via 911.gov): direct dialing, central notification, and the compliance date