Telecom Compliance Guide: Kari’s Law & RAY BAUM’s Act Requirements

Image used for ambiance (eye-candy).

In the hospitality industry, guest safety is paramount. One critical aspect of ensuring safety is compliance with federal regulations regarding emergency communications. Kari’s Law and RAY BAUM’s Act establish essential requirements for multi-line telephone systems (MLTS) to improve emergency response capabilities. Failure to comply not only puts guests and staff at risk but can also result in significant penalties. Here’s what hotel owners need to know about these regulations.

What is Kari’s Law?

Kari’s Law mandates that all MLTS in the United States allow direct dialing of 911 without requiring a prefix (such as dialing “9” first to reach an outside line). The law is named in honor of Kari Hunt, whose tragic death despite her daughter’s attempts to reach 911, underscored the need for unrestricted 911 access. Additionally, the law requires that designated on-site personnel be notified when a 911 call is placed, allowing them to assist emergency responders.

In 2013, Kari Hunt took her children to the Marshall Hotel to meet with their father. Kari was stabbed multiple times during an argument with her estranged husband. Her oldest daughter tried calling 911 four times from the phone within their hotel room, but the calls never went through. She didn’t know that a prefix was required to get an outside line.

Kari’s father, Hank Hunt, turned his grief into action, and made it his mission to ensure no one would experience the struggle Kari’s daughter faced that day. Mr. Hunt succeeded in leading a nationwide movement that resulted in Kari’s Law passing in Congress unanimously in 2018; codifying the need to eliminate any dialing prerequisites for multi-line telephone systems (MLTS). These are typically the phone systems used in large facilities such as office buildings, hotels, or on a university campus.

The effective date provision states that Kari’s Law “shall apply with respect to a multi-line telephone system that is manufactured, imported, offered for first sale or lease, first sold or leased, or installed after” February 16, 2020. It’s time to put the safety of your guests first.

Vertical can help you upgrade your systems, get in compliance, and keep to your bottom line.

What is RAY BAUM’S Act?

RAY BAUM’S is an acronym: Repack Airwaves Yielding Better Access for Users of Modern Services, inspired by the name of the late Ray Baum, a lawyer and congressman who championed this telecommunications policy. The complete Act includes a much broader set of consumer protections to be regulated by the FCC, but Section 506 deals specifically with E911 compliance and defines new standards for multi-line telephone (MLTS) systems.

Much like Kari’s Law, section 506 focuses on ensuring that accurate location information is provided when a 911 call is made from an MLTS. This means that emergency services must receive not just the hotel’s street address but also specific location details, such as the floor number, room number, or building section where the call originated.

240 million 911 calls are made in the US annually. Ensuring specific location data is sent to onsite personnel as well as emergency responders, critical response time is saved.

The first piece of RAY BAUM’s Act, Section 506, covering wired devices, went into effect on January 6, 2021. Wireless and mobile offsite device coverage went into effect on January 6, 2022.

With compliance dates nearly fully past, it’s a good idea to be proactive and immediately implement a future-proof solution that will protect your remote workers and reduce your risk of liability. To make sure you’re fully covered, choose a comprehensive E911 solution that also addresses the requirements of Kari’s Law, which went into effect on February 16, 2020.

What other industries are affected?

Compliance with these laws are “not limited to the hospitality industry. In fact, it’s critically important for any organization that operates multiline telephones systems, particularly those who have remote workers with enterprise numbers. “A recent Metrigy research study of 440 organizations found that just 69.1% of IT leaders responsible for business communications believe that their organizations are compliant with Kari’s Law,” according to Irwin Lazar, Metrigy’s president. This means that 30.9% are NOT compliant, which creates a huge — and potentially very costly — liability problem.” (No Jitter)

Why Compliance Matters

Compliance with these laws is more than just a legal requirement – it’s a critical component of guest and employee safety. When an emergency occurs, quick and effective communication with 911 operators can be the difference between life and death. Compliance ensures that:

  • Guests can reach emergency services without confusion or delay.
  • Emergency responders arrive at the correct location with precise details.
  • Hotel staff are alerted to emergencies and can provide on-site assistance.

How to Ensure Compliance

For hotel owners, compliance requires a proactive approach to evaluating and upgrading their phone systems. Steps to take include:

1 Assess Your Current Phone System

  • Determine if your MLTS requires a prefix to dial 911. If so, modifications are needed to allow direct access.  Example: dialing 9, 911 versus just dialing 911.

2 Enable 911 Call Notifications

  • Configure your system to alert designated staff members whenever a 911 call is placed.

3 Ensure Location Accuracy

  • Work with your MLTS provider to confirm that calls transmit detailed location information, such as room or floor numbers.

4 Train Staff Regularly

  • Educate your employees on emergency response procedures, including verifying that the phone system is functioning correctly.

5 Consult a Compliance Expert

  • Given the technical nature of MLTS compliance, partnering with a telephony expert can help ensure your system meets federal requirements. Call Vertical at 1-877-837-8422 or email us at info@vertical.com to get started.

Penalties for Non-Compliance

Failure to comply with Kari’s Law and the RAY BAUM’s Act can result in substantial penalties. The Federal Communications Commission (FCC) enforces these regulations and can impose fines on businesses that do not adhere to them. Potential consequences include:

1 Fines per violation

  • The FCC can levy fines for each instance of non-compliance to the tune of $10,000 plus $500/day for the period of non-compliance.

2 Liability Risks

  • Non-compliance may expose hotel owners to legal action if an emergency response is delayed due to a failure to meet regulatory requirements.

3 Reputational Damage

  • Guests expect a safe environment, and non-compliance can harm a hotel’s reputation, leading to decreased bookings and negative reviews.

Conclusion

Ensuring compliance with Kari’s Law and the RAY BAUM’s Act is not just about avoiding fines, it’s about protecting lives. Hotel owners must take responsibility for their communication systems to provide guests and employees with seamless access to emergency services. By assessing, updating, and maintaining compliance, hotels can ensure they are meeting legal requirements and  prioritizing safety.

If you need assistance evaluating your current system or implementing necessary upgrades, reach out to our Vertical Experts today to ensure full compliance. The investment in compliance today could save lives tomorrow.