RAY BAUM’S Act is a US federal law passed in 2018 that, among other things, directed the Federal Communications Commission (FCC) to consider rules ensuring that a caller’s dispatchable location, meaning a validated street address plus details such as floor, suite or room, is sent with 911 calls. The FCC’s resulting rules apply to many voice services, including the multi-line telephone systems (MLTS) used in offices, campuses and hotels, and to interconnected VoIP and cloud phone systems. For buyers, it is the reason a phone system project now includes a detailed 911 location plan.
At a glance
- A 2018 US federal law; its 911 provision (Section 506) led to FCC dispatchable location rules.
- Dispatchable location means a street address plus the floor, suite or room details responders need.
- Rules distinguish fixed devices from non-fixed devices such as softphones and roaming phones, with alternatives where automatic location isn’t feasible.
- Usually implemented together with Kari’s Law direct-dial and notification rules as part of E911 setup.
- State laws may add requirements; confirm obligations with counsel or your provider.
What problem it solves
Traditional 911 location relies on the billing or service address tied to a phone line. In a high-rise, hospital, school or multi-building campus, that might be a main street address that tells responders nothing about which floor or wing to go to. With cloud phone systems and remote work, the problem got worse: a softphone call could appear to come from the company headquarters while the person was at home in another city.
The 911 provisions in RAY BAUM’S Act addressed that gap. The FCC rules that followed require providers and system operators to deliver location information precise enough for responders to find the caller, or to use permitted alternatives when that isn’t possible.
How it works
Dispatchable location. For each phone or user, the system needs a validated civic address and, where needed, further detail such as building, floor and room. That location travels with the 911 call to the emergency call center.
Fixed devices. Desk phones and other devices that stay in one place are expected to deliver an automatic dispatchable location, usually set by an administrator when the phone is assigned.
Non-fixed devices. For softphones, mobile apps and devices that move between locations, the rules call for automatic location where technically feasible, for example from network data that maps a Wi-Fi access point or switch port to a location. Where it isn’t feasible, alternatives can include a location the user provides or confirms, or other permitted location information, depending on the service.
Shared responsibility. The provider or manufacturer supplies the capability; the organization typically maintains the location database, assigns locations to phones and keeps them current as people and offices move.
Testing. Many providers offer test calls or test numbers so organizations can confirm the right location is delivered without tying up emergency lines.
The FCC adopted its rules in phases with different dates for different device types, and rules can change, so check the current requirements rather than relying on older summaries. Our Unified Communications as a Service page covers how cloud phone providers handle 911.
When it matters for buyers
- Buying or replacing a phone system. New systems should support dispatchable location for each device type you use.
- Supporting remote and hybrid workers. Softphone and mobile app users need a way to keep their location current.
- Opening, moving or reconfiguring offices. Location records must change when the floor plan does.
- Compliance reviews or audits. You may need to show how 911 location is configured and maintained.
Questions to ask vendors
- How does your platform deliver dispatchable location for desk phones, softphones and mobile apps?
- Can you detect location automatically from our network, and what network data do you need from us?
- What happens when a remote user’s location can’t be determined automatically?
- Who maintains the location database, and how do we update it in bulk?
- How do we test 911 location without placing a live emergency call?
- How do you handle state requirements that differ from the federal rules?
How it differs from Kari’s Law
Kari’s Law and RAY BAUM’S Act are often mentioned together because the FCC implemented them in related rules for business phone systems. Kari’s Law covers dialing: users of covered multi-line systems must be able to dial 911 directly, without a prefix, and the system must notify a central point on site where it can be configured to do so. RAY BAUM’S Act covers location: the FCC rules adopted under it require that the 911 call carry information precise enough for responders to find the caller. A system can meet one and fail the other, so check both.