Telecom Industry Changes - Kari's Law / Ray Baum's Act / STIR/SHAKEN / TRACED Act


#21

What happens when one of your employees on a hosted PBX takes his phone home and plugs it in there without telling anyone in IT that he has done so? It’s going to be a problem when he dials 911…


(Tony Lewis) #22

Of course but that becomes a company policy issue. Our job is to provide the tools needed


#23

Do you have a tool that can automatically identify whether the employee’s phone is at the proper location?


(Tony Lewis) #24

Ya but now go find a service that will do that. My point is how e911 works today with almost every carrier I could find is they are tied to a DID.

What you just described their is close to what we just created the last few months but with a neat module to manage it all in FreePBX so you do not have to type in and remember location tags. You just pick from a drop down of friendly names for your locations.

The other logic issue above is you still do not know which user called if you are using things like 2nd floor northeast corner with our solution we know exactly what extension called as the PBX is handling the notifications.


#25

But a DID is just a number. 212-555-1212-001 is a number. As long as you capture the information and route the call to the correct PSAP along with the CID and location information, everything should work.

Unless, of course, you aren’t providing e911 directly, and are instead using a service provider yourself. In that case, the service provider would need to be on board to allow all of this to be setup on their end…


#26

If you’re referring to notifications, then the ITSP would know which location called based upon the emergency CID that was sent and the stuff we pre-programmed in when e911 was set-up.


(Tony Lewis) #27

Very few carriers have their own PSAP integration. you can count on 1 hand the number approved providers for PSAP integration last time I checked. I think their are 3 main providers of 911 service. Everyone include us buy from these 3.


(Tony Lewis) #28

You missing the point here. That would require every extension to have their own XXX code yet the law only requires general area like 2nd floor northeast corner and that could be 5 different extension in that area. You would NOT know which of the 5 called so that if 911 calls back the front desk knows WHO to send the call back to.


#29

As I said, I expect that they’ll be notifying you of their solution and giving you APIs to interface with it shortly… :slight_smile:

You and everyone else should insist that they not require separate, real DIDs for each location. As you noted, that would indeed be costly and probably lead to DID exhaustion.


#30

I would send it to every phone in that area. As long as the correct phone rings, I would think you’re in compliance. The fact that some incorrect phones also ring shouldn’t change that. Obviously, you’d want to verify this in the rules before you implement.

Another point: With respect to logging in, it would be better if the location could be designated during the user login. That way it would work with any phone.

So, if login today involves dialing a feature code, like *1, i.e.,

*1 + Extension Number + Password

Login tomorrow might be:

*1 + Extension Number + Location Number + Password.


(Tony Lewis) #31

The issue is sending to every phone in the area is if the wrong person answers and knows nothing about what’s going on or what if a extension in that area had call forwarding or follow me and answers remotely now you have to Hangup and try and call the group back again while wasting precious time.


(Tony Lewis) #32

Again we will be having a webinar this week on the full solution we have built so far that we have rolled out to a few dozen very large multi 100 seat installs that we are doing this on for a fraction of what traditional e911 and DIDs for every user would cost.


(Avayax) #33

Can you give me the page number in the document that says that?

If it’s true we’ll use our 24/7 first responders security dept to route 911 calls to.


(Itzik) #34

Hello, Sangoma?

Any word on the issue of Hot Desking phones that are currently not logged in?

As well as the issue of users who work in different locations to update the emergency CID?


(Lorne Gaetz) #35

Work is in progress as noted in the recent community announcement.


(Itzik) #36

Thanks.


(Preston McNair, ClearlyIP CRO) #37

I’ve posted a blog today on Kari’s Law and Section 506 of the Ray Baum Act. In this blog, I outline what your responsibilities are if you plan on selling, leasing, installing, managing, operating, manufacturing, or importing, FreePBX® Based Systems after February 16, 2020.

Admittedly it is a long read just over 3000 words, but considering the FCC Guidelines document for this stuff is over 70 thousand words, I hope this is a pretty good primer as to the details of Kari’s Law and the Ray Baum Act Compliance for the community here. Link to Blog http://zc.vg/wUc9H

As @tonyclewis stated above there will also be a webinar on the same topic this week; you can sign up here https://meetinglab.zoho.com/meeting/register?sessionId=1057547044

Note: All trademarks, service marks, trade names, trade dress, product names and logos appearing in this post are the property of their respective owners :wink:


(Tom Ray) #38

Just a little update if you haven’t seen it. This was the notice of the effective date for Kari’s Law / Ray Baum’s Act. That date is Jan. 6th 2020 so that means certain parties have until Jan 6th 2021 to be compliant and Jan. 6th 2022 for the rest.

Who has until Jan. 6th 2022?

On-Prem MLTS with non-fixed endpoints such as softphones, wifi devices or devices that move locations. It must be able to update the location details automatically or a manual method must be provided. The example was dialing a voice prompt to set the location.

Off-prem devices to the MLTS, Devices that remotely connect to the MLTS and can be at different locations such as a home. So basically for your telecommuters.

Who has until Jan 6th 2021?

On-Prem MLTS with fixed devices (hotels, fixed desk phones, etc) so most of your standard MLTS installs would be under this.

Fixed Telephony Providers/VoIP Interconnects/Outbound Only VoIP Interconnects.

Basically if you have a “standard” MLTS setup for your business where every phone is fixed and doesn’t move regularly you’ve got a year. If you are any sort of provider/interconnect you’ve got a year.


(Preston McNair, ClearlyIP CRO) #39

@BlazeStudios you are correct in stating that there are different dates from the February 16th 2020 date, however, you are intermingling Kari’s Law and the Ray Baum Act here. Although they both, in essence, modify rules and guidelines for the FCC, they are being viewed differently internally.

For new systems or installs the dates are as follows (Note One thing that the FCC has declined to cover at this point is at what level of upgrades (software or hardware) that they are going to determine what you would be required to comply with. They would prefer to work that out on a case by case basis, which to me says, you should C.Y.A. and comply if you run updates on your systems or move to new hardware.):

Compliance dates for Kari’s Law were actually listed in the law, so for those requirements, the FCC has listed an adoption compliance date of February 16, 2020:

  • No Prefix dialing for 911

  • 911 Notification of calls

For providing Dispatchable Location which comes from Section 506 of the Ray Baum Act.

That does have staged implementation dates, as the FCC had their discretion to set adoption dates.

On-Premise - is going to cover the location of the business, as well as any remote facilities or remote phones that are utilized from a regular working location.

Feb 2021 Fixed Devices that are ‘on-premise’ - This would include the obvious hotel phones and desk phones, it would also include phones in which users can utilize hotdesking, as there is no need for someone else to help them move. (although it does make you wonder if the FCC doesn’t understand how IP phones work, you can pick them up and move them to another port on your network within your building, or even another location, and they will still work if registered to a routable system, so that’s bit is going to be fun :slight_smile:
Feb 2022 Non-Fixed that are on-premise - would be Softphones, wifi phones, etc that can be moved, within the premise of the business

Feb 2022- Off-Premise Phones - remote softphones, mobile devices, etc, not located on-prem, this would not include phones in which would be classified as a remote user with a regular workplace (home office etc.).


(Preston McNair, ClearlyIP CRO) #40

Also one other item to note is that the FCC’s regulations are not meant to supplant any existing State Laws requiring MLTS e911. So although the FCC may give you a year, depending on your location you may already have some requirements to provide the specific location of your phones.

For example in Michigan varied (based on size and type of facility) MLTS e911 “dispatchable location” requirements are going into effect this month, they won’t start fining until the end of the year, but once again… CYA… who wants to do an install or configuration twice.

Michigan statute https://www.legislature.mi.gov/documents/2019-2020/publicact/pdf/2019-PA-0030.pdf

Over 20 other states have similar requirements already.

Alaska, Arkansas, Colorado, Connecticut, Florida, Illinois, Kentucky, Louisiana, Maine, Maryland, Massachusetts, Michigan, Minnesota, Mississippi, New Hampshire, Oklahoma, Pennsylvania, Tennessee, Texas, Utah Vermont, Virginia, Washington . All have various laws.