Zoom Phone Nomadic E911: Are You Ready for RAY BAUM’S Act?

In 2019, the Federal Communications Commission (FCC) adopted E911 regulations designed to simplify 911 dialing from business phones and to assist first responders in locating callers who dialed 911 from a business phone. The regulations set deadlines for compliance that vary depending on the type of phone system a business has. 

The last deadline is fast approaching — Jan. 6, 2022 — by which businesses with nomadic or non-fixed multi-line telephone systems (MLTS) like Zoom Phone must comply with the FCC’s new caller location rules. 

Keep reading for some helpful information around these new rules, tips on how to configure your Zoom Phone emergency services, and learn how Zoom can help. For specific guidance regarding FCC compliance, please consult your own legal counsel.  

The FCC adopted rules implementing two federal statutes — Kari’s Law and Section 506 of RAY BAUM’S Act.

Kari’s Law requires direct 911 dialing and notification capabilities in multi-line systems, which are typically found in enterprises such as office buildings, campuses, and hotels. 

Under the statute and the Commission’s rules, MLTS manufacturers and vendors must pre-configure these systems to support direct dialing of 911 — that is, to enable the user to dial 911 without having to dial any prefix or access code, such as the number 9. In addition, MLTS installers, managers, and operators must ensure that the systems support 911 direct dialing.

RAY BAUM’S Act requires multi-line systems to identify the “dispatchable location” of a caller regardless of whether a business uses fixed MLTS, such as an on-premises PBX, or non-fixed MLTS, such as Zoom Phone, as well as for off-premises 911 calls by users who are not located at a business office. 

The FCC defines “dispatchable location” as:

A location delivered to the PSAP [public safety answering point] with a 911 call that consists of the validated street address of the calling party, plus additional information such as suite, apartment, or similar information necessary to adequately identify the location of the calling party.

This is fairly straightforward from a fixed location like your home or a one-building office. Hybrid and remote work environments, however, pose new challenges when employees are spread across multiple locations. 

Under the new rules, it is no longer acceptable to register one general business address if employees are spread across a campus, in a large factory or distribution center, or in-office towers, as it can be challenging for emergency responders to locate someone in distress. This is further complicated if the emergency caller is unable to verbally convey their location to the PSAP.

The FCC compliance deadlines and requirements vary depending on the type of system but are summarized below. For a complete explanation, visit the FCC.gov 911 requirements website.  

• Fixed MLTS (Deadline: Jan. 6, 2021) 
• Non-Fixed MLTS (Deadline: Jan. 6, 2022)
• Off-Premises 911 Calls (Deadline: Jan. 6, 2022)

When someone calls 911, first responders can get to a precise location if the communications system is configured properly. Zoom Phone Nomadic E911 makes it easy to locate callers and alert internal safety team members to the exact emergency if users are spread across locations. Zoom’s Nomadic E911 is designed to comply with both Kari’s Law and RAY BAUM’S Act but requires users to configure the system with just a few steps.

Prior to this legislation, it was common for admins to use the permanent business address as their default location setting. But if your business is in a multi-story building, the phone system must be configured to provide more granular information to the dispatcher or PSAP that goes beyond the general address, and instead, includes the floor, suite, and even room number.

For current Zoom Phone customers, you’ll need to configure your locations by Jan. 6, 2022, to be compliant. 

Zoom Phone fully supports nomadic emergency services for our users natively on the platform without the need for third-party solutions. We’ve made it easy for users to be compliant with the U.S.-based mandates for Kari’s Law and RAY BAUM’S Act by including the proper configurations of existing features.

Configuring essential Zoom emergency services requires three steps:

1. Basic setup: This includes configuring emergency call handling for extension-only users, and turning on emergency notifications. While calls to 911 are "on by default" for users with their own phone numbers, admins must configure emergency call handling for extension-only users. We recommend creating an emergency number pool for each site to simplify the law’s requirement for supporting call-back. With the emergency number pool in place, public safety call-backs will be routed to the originating caller’s extension when an emergency call is placed from within your Zoom Phone system.

Zoom makes it easy to meet Kari’s Law requirements for emergency call notifications by providing multiple notification methods, including:

• Distribution to an email list
• Notifications to Zoom Team Chat, which also provides the capability to post messages to Zoom Rooms Digital Signage
• Webhook alerts
• Integration with third-party event management platforms
• Routing emergency calls in parallel to public safety dispatchers and your Internal Safety Response Team

2. Default emergency addresses setup: To comply with the RAY BAUM’S Act requirements, admins must configure the “dispatchable” emergency address for each company location with granular information such as building number/name, floor, and room number where appropriate. Further, admins should set a corresponding emergency address for common area phones instead of a default business address. 

Users can be prompted to update or confirm their default emergency address by selecting a company address or defining their own personal address. Note: your Zoom Phone admin portal includes policy options to prompt users to update/confirm their addresses and a dashboard to track their progress. 

3. Nomadic emergency services configuration for mobility: To comply with RAY BAUM’S Act requirements for automatically reporting the exact dispatchable location, customers with Zoom Phone users who regularly roam between offices, campus locations, home offices, or hybrid work environments will need to enable Zoom nomadic emergency services. This includes configuring locations for mobile users, testing, and tracking. 

Nomadic emergency services can be enabled at the account or site level. Real-time user location tracking is primarily enabled by translating the user's current network location (IP address, wireless access point connection, network switch port connection) to a real-world physical location with an emergency address. 

Customer admins must configure each detectable Company Location with network data and an emergency address. The Personal Locations feature can be used to enable users to self-define their detectable home office locations. 

You can stay on top of your emergency services deployment with the Zoom Phone location tracking dashboard. 

Whether you are a Zoom customer who has the resources to configure Nomadic E911 but need help to get started, or if you need assistance fully deploying the configuration to ensure you comply with RAY BAUM’S Act, Zoom Professional Services Organization (PSO) is here to help. Our PSO team is experienced in setting up Nomadic E911 for Zoom Phone and can guide your team through the process.

Visit our E911 webpage for helpful demo videos and a best practices guide. Or, watch the on-demand recording of our recent webinar, “RAY BAUM’S Act and Nomadic E911 with Zoom Phone” to see step-by-step configuration instructions, tips to create an emergency number pool, set-up locations and sublocations, and learn how to simplify the process for enterprise businesses with multiple locations.

Jan. 6, 2022, is approaching quickly, so contact your account executive today to discuss your current compliance status and get the help you need. 

Source:
Federal Communications Commission. (2019) Implementing Kari's Law and Section 506 of RAY BAUM'S Act, 911 Access, Routing, and Location in Enterprise Communications Systems, Amending the Definition of Interconnected VoIP Service in Section 9.3 of the Commission's Rules. (Report No. FCC-19-76). https://www.fcc.gov/document/fcc-improves-access-911-and-timely-assistance-first-responders-0