kari’s law & ray baum’s act compliance fact sheet · the party must receive notice of the...

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Next Generation 911 provides granular, potentially life-saving, location information. Consider that businesses like yours have nearly 2 million workplace violence incidents a year. When seconds count, your coworkers and customers need first responders to be able to reach them as quickly as possible. Unfortunately, most business phone systems fail to deliver on these requirements. Configuration and technical barriers often prevent a 911 operator from getting the information they need to assist you. The case of Kari Hunt Dunn brought national attention to this problem when she became a victim of homicide in a Texas motel room, and her 9-year old daughter attempted to call the police. She could not reach them by dialing “9-1-1” because the child did not know the motel’s phone system required an access code of “9” to be dialed first. In response, Congress enacted two laws to address this unfortunate incident and provide a framework for including detailed location with every 911 call made across the country. Kari’s Law requires direct “9-1-1” dialing and notification capabilities. The law took effect February 16, 2020, and requires a phone system to allow a user to call 911 directly, notify another party of the emergency call in progress, and report the location to onsite staff. The second law, Ray Baum’s Act, requires sending dispatchable location information to public safety with every 911 call. Historically, just a street address was provided but detailed information such as the floor, building number, suite, office number, etc., should now be included to help first responders find the caller. Ray Baum’s requirements begin to take effect January 6, 2021, and are enhanced on January 6, 2022, for non-fixed systems. Noncompliance comes with stiff penalties, up to $10,000 fines and $500-per day penalties and a possible prison sentence. Kari’s Law & RAY BAUM’s Act Compliance Fact Sheet VISIT covene.com/e911 FOR MORE INFORMATION

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Page 1: Kari’s Law & RAY BAUM’s Act Compliance Fact Sheet · The party must receive notice of the following three items to be compliant: a. Notice the emergency call occurred, b. A callback

Next Generation 911 provides granular, potentially life-saving, location information.

Consider that businesses like yours have nearly 2 million workplace violence incidents a year. When seconds count, your coworkers and customers need f irst responders to be able to reach them as quickly as possible. Unfortunately, most business phone systems fail to deliver on these requirements. Configuration and technical barriers often prevent a 911 operator from getting the information they need to assist you.

The case of Kari Hunt Dunn brought national attention to this problem when she became a victim of homicide in a Texas motel room, and her 9-year old daughter attempted to call the police. She could not reach them by dialing “9-1-1” because the child did not know the motel’s phone system required an access code of “9” to be dialed f irst.

In response, Congress enacted two laws to address this unfortunate incident and provide a framework for including detailed location with every 911 call made across the country. Kari’s Law requires direct “9-1-1” dialing and notif ication capabilities. The law took effect February 16, 2020, and requires a phone system to allow a user to call 911 directly, notify another party of the emergency call in progress, and report the location to onsite staff.

The second law, Ray Baum’s Act, requires sending dispatchable location information to public safety with every 911 call. Historically, just a street address was provided but detailed information such as the floor, building number, suite, off ice number, etc., should now be included to help f irst responders f ind the caller.

Ray Baum’s requirements begin to take effect January 6, 2021, and are enhanced on January 6, 2022, for non-f ixed systems. Noncompliance comes with stiff penalties, up to $10,000 fines and $500-per day penalties and a possible prison sentence.

Kari’s Law & RAY BAUM’s Act Compliance Fact Sheet

VISIT covene.com/e911 FOR MORE INFORMATION

Page 2: Kari’s Law & RAY BAUM’s Act Compliance Fact Sheet · The party must receive notice of the following three items to be compliant: a. Notice the emergency call occurred, b. A callback

Q&A Kari’s Law & RAY BAUM’s Act Compliance Fact SheetQ&A

Covene - Denver & St. Louis - 833-4COVENE - www.covene.com2

Do these laws apply to me?

If you are purchasing a new phone system, yes, the law applies to you.

If you have an existing telephone system in your business, you will likely be subject to the laws,especially after an upgrade.Please, discuss the law and its impact with your legal counsel and technical advisors like Covene. We can provide a technical assessment of your compliance posture and couple this with your counsel’s legal opinion.

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What happens after the various compliance dates?

Your organization is responsible for compliance with each of the requirements. You can leverage services from Covene to become compliant and then operate the systems yourself or engage Covene Managed Services to operate these systems and maintain compliancy on your behalf.

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How does Kari’s Law apply to a company’s phone system?

Configure your system such that callers can place a 911 call without the need to dial a prefix. Note, do not need to disable patterns such as “9-911” if they exist.

Your system must notify another party within or outside your business. The party must receive notice of the following three items to be compliant:

a. Notice the emergency call occurred,b. A callback number for the party placing the 911 call, andc. Information about the location of the call, such as address and other location

information that was sent to the PSAP during the 911 call.

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How does RAY BAUM’s Act apply to a company’s phone system?

Your phone system must send dispatchable location information, which is generally information such as the building number, street address, floor number, room number, or other similar information that can be used to identify the calling party.

The FCC requires dispatchable location information to be sent automatically by the phone system, not rely on the caller relaying it to the 911 operator.

You must comply with this law by 2021 for f ixed phone systems and 2022 for remote users.

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Page 3: Kari’s Law & RAY BAUM’s Act Compliance Fact Sheet · The party must receive notice of the following three items to be compliant: a. Notice the emergency call occurred, b. A callback

Q&A Kari’s Law & RAY BAUM’s Act Compliance Fact SheetQ&A

Covene - Denver & St. Louis - 833-4COVENE - www.covene.com 3

Where can I get more information about the laws?

The FCC website contains helpful information about compliancy and the law text. Please refer to the FCC post; available here: https://docs.fcc.gov/public/attachments/FCC-19-76A1.pdf

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How does Covene help me become and stay compliant?

We will configure dial plan modif ications to support Kari’s Law compliance, configure tools like Emergency Responder (CER), and couple CER features with services from 911 service providers for E-911.

With Covene Managed Services, we can ensure your system remains compliant with both Kari’s Law and RAY BAUM’s Act.

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I’m considering a new phone system, what does Cisco provide to help me be compliant?

If you utilize Covene for your deployment, we will deploy your Cisco Unif ied Communications platform to be fully compliant with Kari’s Law and the RAY BAUM Act.

If you are configuring your system, a new wizard from Cisco will help you configure a route pattern for direct dial calls to 911. Ensure you do not configure any overlapping patterns, which can cause the system to wait 15 seconds, by default, for the interdigit (T302) timer.

To be compliant with RAY BAUM, you’ll need to use the Native Emergency Calling feature or the Cisco Emergency Responder (highly recommended) application.

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Page 4: Kari’s Law & RAY BAUM’s Act Compliance Fact Sheet · The party must receive notice of the following three items to be compliant: a. Notice the emergency call occurred, b. A callback

Q&A Kari’s Law & RAY BAUM’s Act Compliance Fact SheetQ&A

Covene - Denver & St. Louis - 833-4COVENE - www.covene.com4

What about remote workers using VPN phones, softphones, and similar tools?

Everyone must be able to call 911 directly. Kari’s Law applies to any user connected to your phone system, regardless of how they connect or where they are located.

Under Ray Baum’s Act, the enhanced location information is optional but highly recommended. By utilizing a 911 service provider coupled with Cisco Emergency Responder, you can provide remote workers an easy way to populate their home address, or remote working location, for f irst responders to access the caller.

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I don’t have Cisco Emergency Responder or E911, how do I get it?

You can create a price estimate ofan Emergency Responder & E-911 deployment, as well as contact Covene for detailed pricing at our dedicated site for E-911 information: https://www.covene.com/e911

If you are covered by a Cisco Flex Plan agreement, you may be entitled to free Emergency Responder licensing.

911 compliance software can be purchased with or without Emergency Responder and as a one-time or recurring subscription purchase.

I have an existing Cisco phone system, what do I need to do, and how much will it cost?

Kari’s Law compliance will require your dial plan support 911 calls without a prefix. Covene offers a compliance and remediation package to configure your dial plan for Kari’s Law compliance and provide a planning document for RAY BAUM’s compliance in 2021.

For RAY BAUM’s Act compliance costs, you can use the Covene E-911 Compliance Pricing tool to calculate costs for licensing, service costs, and implementation fees; available here: https://www.covene.com/e911

To implement compliancy with RAY BAUM’s Act on your own, we strongly recommend Cisco Emergency Responder and a 911 service provider for automated E911 location synchronization.

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Page 5: Kari’s Law & RAY BAUM’s Act Compliance Fact Sheet · The party must receive notice of the following three items to be compliant: a. Notice the emergency call occurred, b. A callback

Q&A Kari’s Law & RAY BAUM’s Act Compliance Fact SheetQ&A

Covene - Denver & St. Louis - 833-4COVENE - www.covene.com 5

How does this work with features like Extension Mobility or Extension Mobility Cross-Cluster?

We recommend utilizing Cisco Emergency Responder for all E-911 compliancy needs. The product is intelligent and aware of features such as EM and EMCC to properly track the phone and maintain compliance with both laws.

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I have analog phones, how can they be tracked?

Covene will configure your Cisco Emergency Responder software to accurately use and provide location information for emergency calls.

If you are configuring the system, remember analog phones aren’t tracked the same way as IP Phones and will require manually defining the directory number in Emergency Responder or configuring an IP Subnet for the device.

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I have non-Cisco switches or phones that sit behind third-party switches, what do I do?

Covene can ensure these phones are enabled to accurately send enhanced location information by using features in Emergency Responder such as IP Subnet or manual location configuration.

What is meant by Kari’s Law notification requirement?

Notif ications can be visual alerts on a monitor, an audible alarm, text or email messages, phone calls to designated parties, or an application running on a computer. The law does not directly specify the method or medium, but these are generally accepted guidelines for notif ications.

Recall, the notif ication must include an alert that a 911 call has occurred, a callback number, and information about the caller’s location.

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Page 6: Kari’s Law & RAY BAUM’s Act Compliance Fact Sheet · The party must receive notice of the following three items to be compliant: a. Notice the emergency call occurred, b. A callback

Q&A Kari’s Law & RAY BAUM’s Act Compliance Fact SheetQ&A

Covene - Denver & St. Louis - 833-4COVENE - www.covene.com6

Sources: 1. Kari’s Law Act of 2017, Pub. L. No. 115-127, 132 Stat. 326 (2018) (codif ied at 47 U.S.C. § 623) (Kari’s Law)2. Section 506 of the Repack Airwaves Yielding Better Access for Users of Modern Services Act of 2018 (RAY BAUM’S Act),

Pub. L. No. 115-141, 132 Stat. 348, 1095 (codif ied at 47 U.S.C. § 615 note)3. FAQ’s for MLTS Operators - https://www.fcc.gov/f iles/mltsfaqspdf4. 911 Requirements for MLTS – 47 C.F.R. Part 9, Subpart F5. Public Notice of Kari’s Law and RAY BAUM Act - https://docs.fcc.gov/public/attachments/DA-19-1236A1.pdf

How can I confirm accurate location information is being sent to and received at the PSAP?

Covene provides audits of every location configured in Emergency Responder and 911 service providers during implementation. We provide all test reports as certif ied proof your system is configured correctly.

We recommend you audit your emergency location transmissions at least once a year to confirm proper information is populated.

In all cases, please coordinate with your PSAP before you place a 911 call to avoid inadvertent dispatches of f irst responders and potential fees.

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Who should be notified?

There is no requirement for a specif ic job function, but rather the notif ication must be sent to the people who need to know the call occurred. We recommend any receptionist, security personnel, system administrators, and local emergency response team personnel, be included in the notif ication.

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