Kari's Law and Ray Baum's Act: Is Your Building Compliant?

Kari’s Law and Ray Baum’s Act have applied to multi-line telephone systems since February 16, 2020. Kari’s Law requires that a caller reach 911 by dialing those three digits and nothing else, and that someone on site is told the call happened. Ray Baum’s Act requires that the location sent to the dispatcher be specific enough to find the caller, which means the building rather than the account address. A system can satisfy both on paper and still fail on the call that matters, because both requirements depend on how the system was configured per building and on whether anyone has tested it since.

How to tell whether your building complies with Kari’s Law and Ray Baum’s Act

There are four checks, and all four are testable this week without a purchase or a vendor visit.

1. Dial 911 directly from a desk phone. No 9, no 8, no outside-line prefix. If the call needs a prefix, the system does not comply with Kari’s Law, full stop.
2. Confirm the address the dispatcher sees. Coordinate a live test call with your local PSAP in advance, then ask the dispatcher to read back the address and any location detail they received. If they read the account address instead of the building the call came from, Ray Baum’s Act is not satisfied.
3. Check who was notified, and whether they are still employed. Kari’s Law requires an on-site notification when a 911 call is placed. Open the notification list. Most lists we open still route to a front-desk address or a phone number that belonged to someone who left.
4. Repeat both calls from every building, and from a device that moves. A district or a county passing the test at the main office proves nothing about the annex, the bus garage, or the field house. Softphones and mobile app users need their own check, because their location is not fixed to a jack.

Write down what failed. If the phone system cannot pass check 1, that is a platform problem. If it fails checks 2 through 4, that is usually configuration, and configuration is an afternoon of work rather than a project.

Kari’s Law

In 2013, Kari Hunt was attacked and killed by her estranged husband in a hotel room in Marshall, Texas. Her nine-year-old daughter was with her and tried calling 911 four times from the hotel room phone. The hotel system required guests to dial 9 for an outside line, including for an emergency call. Her daughter did not know that. None of the calls went through.

Kari’s father, Hank Hunt, worked with the FCC and Congress to require that every multi-line telephone system reach 911 on those three digits alone. That work became Kari’s Law.

The law applies to the systems found in hotels, schools, corporate offices, and call centers. Two obligations come with it. A person dialing 911 must be connected directly, with no prefix. And the system must notify a front desk, a security office, or another designated person on site when the call is placed, so that responders can be met and let in.

Ray Baum’s Act

Section 506 of Ray Baum’s Act covers what the dispatcher receives. It passed in 2018. The location sent with a 911 call has to be a dispatchable location: a street address plus enough detail to find the caller inside it, such as building, floor, suite, or room. The requirement applies to fixed devices and to non-fixed devices on the same system, which is the part that catches organizations with softphones and mobile users.

The two laws are usually discussed together because they cover opposite ends of the same call. Kari’s Law governs whether the call connects and who on site hears about it. Ray Baum’s Act governs whether a responder can find the caller once it does.

Where organizations actually fail

We find the same four failures nearly everywhere we test.

One address for every building. The account was set up with the main address and every site inherited it. An emergency call from a building three miles away presents at the district office.

A notification list nobody maintains. The list was built at cutover with whoever held the front-desk role that year. Two years of turnover later it points at a mailbox nobody reads.

Devices that moved and location that did not. A handset gets carried to a different building during a renovation, or a staff member works from the app. The location record still reflects where the phone was installed.

A test that was never run. This is the most common finding by a wide margin. Compliance gets assumed at cutover and never verified again, so the first real test of the configuration is a real emergency.

What a compliant system looks like

Our hosted unified communications platform dials 911 directly, sends the on-site notification by email, SMS, and in-app alert to whoever the organization designates, and carries a per-building dispatchable location rather than one address for the account. Where a site needs the alert to reach a wider group, the same call can trigger mass notification or an overhead page.

Configuration is still the organization’s decision and it is where compliance is won or lost. We build the per-building records with the customer at cutover, then run the live PSAP test with them at every site and write down what the dispatcher read back.

If you want a second set of eyes on your own test, call us at 855-878-8477. K-12 districts can start with the building-by-building version of this check in the K-12 phone system evaluation checklist.

Frequently Asked Questions

Does Kari’s Law apply to my organization?

It applies to any multi-line telephone system installed, manufactured, imported, or sold for use in the United States after February 16, 2020. That covers most schools, hotels, offices, medical practices, and government buildings. Systems installed before that date are asked to comply where it is economically feasible, and in practice a system that still needs a 9 to reach 911 is a liability regardless of when it went in.

What counts as a dispatchable location?

A street address plus enough additional detail for a responder to find the caller: building, floor, suite, or room, depending on the size of the site. A single street address for a multi-building campus does not satisfy Ray Baum’s Act, because it does not tell a dispatcher which building to send responders to.

Who has to receive the 911 notification under Kari’s Law?

The organization designates the recipients. The requirement is that someone on site is told, so the notification has to reach people who can actually respond and let responders in. A front desk, a school office, a security desk, and a facilities lead are typical. The notification can go by email, text, or an alert on a phone, and it should go to more than one person so a single absence does not break it.

How do I test 911 compliance without tying up a dispatcher?

Call your local PSAP’s administrative line first and schedule the test. Most are willing to coordinate, and many prefer it to discovering a bad address during a real call. Place the test call and ask the dispatcher to read back the address and location detail they received. Confirm separately that the on-site notification fired. Do this once per building.

Our phone system was installed before 2020. Are we grandfathered in?

Only in a narrow sense. The FCC’s rules ask pre-2020 systems to comply where it is economically feasible rather than requiring a replacement outright. That is a weaker obligation than the one on new systems, and it is not a defense if an emergency call fails because the system needed a prefix. Most organizations in this position find the fix is a configuration change or a hosted replacement rather than a rebuild.

Does a mobile app or softphone user need a dispatchable location?

Yes. Ray Baum’s Act covers non-fixed devices on a multi-line system, which is exactly what an app user is. The practical answer is a registered location per user that they can update when they move, plus a prompt at 911 dial time on platforms that support one.