E911 is Not a Joke: Does Your Multiline Telephone System (MLTS) Make the Grade?

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The Federal Communications Commission (FCC) has issued rules that may require organizations using multiline telephone systems (MLTS) to implement enhanced 911 (E911) on those systems.

Multiline telephone systems are commonly found in businesses and educational facilities, including corporate parks, hotels, campuses, and planned community developments. MLTS includes all circuit-switched and IP-based enterprise systems, and cloud-based IP technology and hybrid systems.

Organizations should evaluate whether their MLTS systems are subject to the FCC’s rules, and whether existing systems as upgraded or new systems as implemented may fall under the rules.

What is Enhanced 911?

E911 was designed to ensure that the public can successfully dial 911 to request emergency services, and that Public Safety Answering Points (PSAPs) can quickly and accurately locate every 911 caller. Consumers using landline, wireless, and Voice over Internet Protocol (VOIP) generally have access to E911 capabilities when they make calls to 911. However, consumers in MLTS environments historically may have not had the same access to E911 services (direct dialing access to 911 and the provision of location information) as other consumers. For example, some MLTS systems require an initial step to activate the phone line, such as dialing “9” for an outside line.

The FCC’s rules were adopted in part to implement a 2017 statute called “Kari’s Law,” named in honor of Kari Hunt, who was killed by her estranged husband in a motel room in Marshall, TX in 2013. Ms. Hunt’s nine-year-old daughter tried to call 911 from the motel room phone, but the call never went through because she didn’t know she needed to press “9” to access an outside line.

What’s Changed (or is Changing)?

The FCC’s rules ensure that MLTS systems are E911-compliant. The rules require any MLTS manufactured, sold, or installed after February 17, 2020 to:

1. Allow direct 911 dialing (e.g. no requirement to dial “9” first);
2. Notify the organization that a 911 call has been placed; and
3. Convey “dispatchable location” information to the PSAP.

Crucially, an existing MLTS that receives “improvements” or “substantial upgrades” after February 17, 2020 is subject to these requirements.

The January 6, 2022 Deadline: There’s Not a Minute to Spare

The FCC set various implementation deadlines for compliance with its rules, based on the technology used to make calls. Some of these requirements have already gone into effect. Those organizations using on-premises “non-fixed” services (including interconnected VOIP services) and off-premises devices must implement the “dispatchable location” requirements by January 6, 2022.

Conclusion: Don’t Wear the Late Crown

The FCC possesses the authority to enforce these rules. As a result, all organizations must evaluate their current and future MLTS systems to ensure compliance with these standards.

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