COMMENTARY FROM COUNSEL
HOLD THE PHONE: FINAL 911 COMPLIANCE REGULATIONS EFFECTIVE JANUARY 2022 An important deadline that may affect your agency and its clients has arrived. January 6, 2022 marks the final compliance deadline for a series of regulations adopted by the Federal Communications Commission (FCC) to implement Kari’s Law and Ray Baum’s Act—two federal laws that strengthen emergency calling. Like many laws, these new requirements are named, in part, after a tragic situation and aimed at avoiding similar problems in the future. What Are The New Laws? Kari’s Law requires organizations that use Multi-Line Telephone Systems (MLTS) to provide callers with direct dial access to 911 call centers without requiring entry of a prefix to connect to an outside line. Congress passed Kari’s Law in memory of Kari Hunt, a young mother who was murdered by her estranged husband in a Texas motel room. Her 9-year-old daughter tried to call 911 four times from the motel phone but was unable to reach a 911 dispatch center because she did not know she had to dial 9 before dialing 911. Ray Baum’s Act expands on Kari’s Law to require a “dispatchable location” to be transmitted when a 911 call is made from a MLTS. Ray Baum is both an acronym, Repack Airwaves Yielding Better Access for Users of Modern Services, and the name of a lawyer, politician, and lobbyist who worked closely with the FCC on various telecommunication issues.
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wisconsin INDEPENDENT AGENT
Together, Kari’s Law and Ray Baum’s Act make it easier for people to contact 911 emergency services and for first responders to locate and help people. Through a phased compliance program, the FCC has committed to widespread enforcement of its implementing regulations with penalties for organizations that fail to comply. With the recent passing of the final compliance deadline, organizations should not delay understanding their responsibilities and potential exposure for non-compliance. Is your business covered? Kari’s Law and Ray Baum’s Act apply to any person engaged in the business of manufacturing, importing, selling, leasing, installing, managing, or operating a MLTS and any MLTS that is manufactured, imported, offered for first sale or lease, first sold or leased, or installed after February 16, 2020. The FCC’s implementing regulations define a MLTS as “a system comprised of common control units, telephone sets, control hardware and software and adjunct systems, including network and premises-based systems, such as Centrex and VoIP, as well as PBX, Hybrid, and Key Telephone Systems… and includes systems owned or leased by governmental agencies and non-profit entities, as well as for profit businesses.” Stated another way, it is a phone or other calling system with more than one line.
