How do Kari’s Law and Ray Baum's act affect VoIP providers?

Ray Baum's Act and E911 Requirements

Ray Baum's Act, specifically section 506, mandates that any multi-line telephone system (MLTS) used by telecom companies or VoIP service providers, like Flowroute, must be capable of providing 911 dispatch for any location in the United States. Flowroute requires public-safety answering point (PSAP) information when associating an Enhanced 911 (E911) address to a telephone number (TN). When using the Flowroute E911 product, customers provide the necessary identifiable information for emergency dispatch services.

The Act has expanded the scope of VoIP providers required to offer E911 services. To comply with this, Flowroute has implemented a 911 Fee starting February 1, 2022. This fee helps cover legal and regulatory charges, including increased state and local taxes on E911 services.

We are committed to providing technical assistance as needed.

IMPORTANT: Responsibility is ultimately up to the MSP or whoever manages the phone system to cite local requirements for compliance with Ray Baum's Act and Kari's Law. For example, some states require you to have an Enhanced DID for each room/suite in a building, or for each building on a campus, etc.

Below are answers to some common questions.

FAQ

What is E911?

E911 is an emergency dispatch's locational information to provide the correct responders. When this information is present in the Flowroute account, the dispatch can find the accurate locality for the services which need to be made aware.

How does E911 apply to Flowroute?

Flowroute provides the dispatch with the E911 information associated with the account, specifically the DID that called 911.

Is my account impacted?

The E911 fee applies to all Flowroute accounts with a DID E911 enabled. For local telephone numbers (TNs) accounts, the E911 fee will be $1.50 per month per local E911 enabled TN. Accounts with no enabled DID E911 addresses will not incur any fee.

What if I have one or more telephone numbers?

If the account has one or more telephone numbers, the E911 fee is charged for each E911 enabled TN. For example, if you have 3 TNs on the account with E911 enabled, the E911 fee is $1.50 x 3 = $4.50 per month.

Are toll-free telephone numbers subject to this fee?

No. An account with Toll-Free TN(s) will not be charged a per toll-free DID fee.

What is the difference between the $1.39 MRC I'm currently paying for "E911 enabled per phone number" and the new $1.50 MRC?

The $1.39 fee covers the monthly use of the E911 service setup that automatically associates a physical address with the calling party's telephone number. When you enable E911 addresses to your numbers, an emergency call to 911 will be routed to the correct local dispatch center and allow the dispatchers to retrieve the address location. The $1.50 fee is necessary to recover legal and regulatory charges arising from Flowroute's compliance with Ray Baum's Act, including increased state and local taxes on E911 services.

What are the requirements for using E911?

E911 is a user-established, and user-applied data point that Flowroute will need. The Flowroute account will house this E911 information as an optional selection. The crucial need to use an E911 effectively is to assign that E911 address in the Flowroute account to a specific DID. If the DID has the E911 info applied, the next step is to ensure that the PBX using the Flowroute account uses that DID for the outbound caller ID when connecting to 911. If the outbound caller ID is not associated with any direct E911 address, the call will connect but seek additional information from a dropped call.

Flowroute does not offer E911 compliance consultation as part of its services. Refer to the government resources linked at the bottom of this article for additional information on exact requirements.

Will Flowroute connect an E911 call if no E911 address is assigned?

Yes. Flowroute will connect any call using its network to 911, and having no E911 assignments does not impact the connection. Suppose an E911 address is not associated with any DID on the account. There is a $95 fee to gather the approximate location of the call manually.

Who is exempt from the E911 fee?

  • Customers presenting valid USF exemption certificates, upon validation by Flowroute, would be exempt from the E911 fee.  

  • DIDs with no E911 enabled will not be charged.

  • Accounts with no US DIDs.

How do Kari's Law and RAY BAUM'S Act impact Flowroute's E911 system?

Kari's Law is a subsection that was later added into Ray Baum's Act, which states that anyone must be able to reach a 911 call center when directly dialing 911 from an MLTS. The goals of Ray Baum's Act and Kari's Law are to ensure standardization and reliability for any calls made from an MLTS or VoIP provider service, like the service Flowroute provides, in order to precisely locate a 911 caller. The location information that's passed is essential in high-rise buildings and multi-floored locations that may employ VoIP PBX systems. Flowroute provides SIP service, enabling a PBX to work as a company telephone system. Under Kari’s Law, the process of dialing 911 must be directly accessible without any pre-dial.

Contextually, the incident behind Kari's Law was due to an inability to dial 911 effectively and predictably. The incident led to a death because the caller was unfamiliar with a motel's pre-dial requirement to dial "9" before dialing "911" in order to call out to emergency services. Now, MLTS and VoIP service providers in the United States must connect to 911 without any additional dialing requirement.

This demonstrates the potential for custom requirements to confuse users and impede emergency communication. This is why phone systems and providers MUST allow end users to simply dial "911" and be connected with emergency services, along with the phone system transmitting a corresponding caller ID that provides exact location information for the PSAP to respond to for that call, and a direct telephone number to call the requester back if necessary.

The RAY BAUM'S Act requires any outbound 911 to connect.

The 911 dispatch will provide the dispatch with the stored E911 address assigned to that DID. Emergency responders must manually locate the caller if the dispatch is not supplied with an E911 address.

A manual lookup will come with a $95 fee to perform this service on a per call basis.

This new act ensures the caller's safety, decreases emergency response times, and offers precise information about the location of the call.

How to get support

For support assistance, please submit a ticket, or call +1 (855) 356 9768 and use option 8.

Resources

[External] FCC.gov - 911 Requirements for Multi-line Telephone Systems

[External] ECFR - VoIP Services & E911 Service

[External] 911.gov - Kari’s Law and Ray Baum’s Act