Kari’s Law was signed into law on February 16, 2018 and went into effect on February 16, 2020. The law provides requirements for direct emergency call dialing and notification of on-premises personnel when someone makes an emergency services call. The notification is to help facilitate access to the building and the emergency caller by first responders. While not clearly stated, the law infers that when a user places a call to emergency services that the call will be routed by the customer’s telephone services to a Public Safety Answering Point (PSAP). State and municipal laws and regulations can supersede Federal laws as long as they are not inconsistent with them.
Direct Emergency Dialing Requirement
Under Kari’s Law, a multi-line telephone system (MLTS) must be configured to not require a United States based emergency services caller to dial any number other than 911. In the past, there have been MLTS systems that have required that emergency services be dialed with number strings such as 9911. That is no longer allowed. The implementation of this requirement is simple for both Microsoft Teams Calling Plan and Direct Routing users.
Microsoft Teams Calling Plan Users
- You do not need to do anything to comply with this requirement. Teams Emergency Call Routing Policies do not need to be configured to support Calling Plan users nor are they applicable
- Teams recognizes calls dialed as “911” as Emergency Calls and will treat them as such
- Microsoft also supports the test number, “933”. Dialing this will connect the caller with a bot that will read back the Calling Number and the current location of the user if it can be determined. If not, it will read back the caller’s address of record
- If you setup a custom Dial Plan for your Teams Calling Plan users, you must make sure that the rules in the plan do not conflict or impede the users ability to dial 911 or 933 and complete emergency services calls
Microsoft Teams Direct Routing Users
- Teams Emergency Call Routing Policies must be configured if you are implementing Teams Direct Routing
- The policies can be found in the Teams Admin Center by clicking on “Voice” then “Emergency policies” and “Call routing policies” at the top of the page
- The Teams PowerShell commands to manage Emergency Call Routing Policies are:
- Most US based tenants will only need the Global Emergency Call Routing Policy. If there is more than one (1) Direct Routing Session Border Controller (SBC) a client may add a second policy. Adding a second policy can be easily accomplished in the Teams Admin Center
- Teams provides two (2) policies by default that cannot be deleted:
- The Global policy is automatically applied to all Teams Direct Routing users. The TestECRP is an example of a user level policy. This type of policy can be directly assigned to individual users or to Teams Tenant Network Sites
- The scoping of these policies to Tenant Network Sites is covered in another blog in this series
- Both provided policies are set with “Dynamic Emergency Calling” disabled meaning that as configured, the policies do absolutely nothing!
- Emergency Call Routing Policies have two (2) purposes:
- Allow direct emergency services dialing
- Properly route emergency calls from Direct Routing users to the SBC(s)
- The emergency numbers that Teams Direct Routing Users can dial are controlled by the Teams Emergency Call Routing Policy.
- The Emergency Call Routing Policy is also used to route the call to the customer’s SBC(s). The SBCs will then route the calls to an Emergency Routing Service Provider (ERSP) before they are routed to the appropriate PSAP. This satisfies the implied requirement of Kari’s law that emergency calls be routed to the appropriate PSAP
- If no Emergency Call Routing Policies have the “Dynamic Emergency Calling” option enabled, Teams will not be able to properly identify a call to emergency services
- Teams will not send notifications to internal monitoring personnel. This would leave the Company in violation of Kari’s Law.
- Configuration of emergency services calling in this case wilwill require the proper configuration of the user’s effective Teams Dial Plan and Teams Online Voice Routing Policy.
- The Teams Dial Plan must be configured to support placing calls to emergency services by dialing “911”.
- The user must have a Teams Online Voice Routing Policy that can route emergency services calls to SBCs that can pass the call to an ERSP and the PSAP
- There are four (4) attributes in the Emergency Call Routing Policy that control direct emergency dialing:
- Dynamic Emergency Calling
- Emergency Dial String
- Emergency Dial Mask
- PSTN Usage
Dynamic Emergency Calling
- This switch turns on Dynamic Emergency Calling for Teams Direct Routing users
- If the switch is turned off, you will have to address emergency services calling and routing in Teams Dial Plans and Teams Online Voice Routing Policies for your Teams Direct Routing users to comply with the Direct Emergency Dialing requirement of Kari’s Law
- Dynamic Emergency Calling must be enabled to be able to configure Teams to be in compliance with the automatic location requirement of the RAY BAUM act using the built-in capabilities of Teams
Emergency Dial String
- The Emergency Dial String is the phone number that will be sent to the SBCs when a Direct Routing user makes an emergency services call
- Emergency Call Routing Policies can include more than one Dial String. Each must be unique
- In the United States, “911” will be the most common Dial String added to Emergency Call Routing Policies. In some cases, the number passed will be different
- If your ERSP supports it, “933” will almost always be added as a Dial String in an Emergency Call Routing Policy
Emergency Dial Mask
- Each Emergency Dial String can have one or more Emergency Dial Masks separated by a semi-colon
- The masks are used to identify emergency calls based on the various ways a user might dial an emergency call.
- In the United States “911” should always be added as a mask to comply with Kari’s Law. Even if it is remotely possible that a user might inadvertently dial “9911”, you should add this mask.
- Most European and Asian users are used to dialing “112” to reach emergency services. It may be prudent to add this mask in case a visiting European or Asian colleague dialed “112” instead of “911”
- There is a myriad of other emergency numbers foreign visitors to a Company’s offices might dial. They should be added as needed
- The PSTN Usage are Teams telephony objects that contain Teams Voice Routes. An in depth discussion of Teams Voice Routing is beyond the scope of this article. To get more information on the subject please review Configure voice routing for Direct Routing
- Teams Voice Routes are what are used to route emergency calls to the Company’s Direct Routing SBC(s)
- In most cases, there will be one PSTN Usage and one Voice Route for each Direct Routing SBC
- Company’s may have more than one Direct Routing SBC for geographic reasons, redundancy, etc. In these instances you will almost always need more than one Voice Route, PSTN Usage and Emergency Call Routing Policy for emergency calling
Typical Teams Emergency Routing Policy
- Following is a sample Teams Emergency Call Routing Policy for:
- A United States based tenant
- One Direct Routing SBC resulting in a single PSTN Usage named “Emergency” and a single Voice Route also named “Emergency”
- The Voice Route will match if the called number is 911 or 933 and will route these calls to the SBC
- If your ERSP does not support a test number, delete the Dial String for 933:
- The notification requirement of Kari’s law is used to facilitate building entry by first responders
- When a call to Emergency Services is made a notification must be sent to an on-site or off-site central location where someone is likely to see or hear the notification
- The notifications must be a conspicuous on-screen notification with an audible alarm through a client application, smartphone text message or email
- The notification shall at a minimum include:
- The fact that a 911 call has been made
- A valid callback number and,
- The information about the caller’s location that the MLTS provides to the Emergency Services provider with the 911 call; provided, however that the notification does not have to include a callback number or location information if it is technically infeasible to provide the information
- Teams Emergency Calling Policies are used to meet the Notification requirement of Kari’s Law
- They are applicable to both Teams Calling Plan and Teams Direct Routing users
- The policies can be found in the Teams Admin Center by clicking on “Voice” then “Emergency policies” and “Calling policies” at the top of the page
- The Teams PowerShell commands to manage Emergency Calling Policies are:
- It may be easier to add these policies through PowerShell if you have a lot of them. Otherwise, add them through the Teams Admin Center
- Teams provides one (1) policy by default that cannot be deleted:
- The Global policy is automatically applied to all Teams users. No notifications are enabled in this policy by default
- If you want to send all notifications to the same user(s), you will probably only need the Global policy for your Company
- You can create additional policies that can be used to assign different notification users and group to different user population.
- For example:
- You may configure policies for each building. Emergency calls made by a user connected to a subnet in a given building would result in a notification being sent to users and groups designated to cover that building
- You can configure a policy for users homed in buildings on the East Coast and a separate one for those on the West Coast
- You can create policies that are directly applied to individual users or to one or more Teams Tenant Network Sites
- The scoping of these policies to Tenant Network Sites is covered in another blog in this series
- For example:
Configuring a Teams Emergency Calling Policy
The policies have five (5) attributes:
- A user with Teams administrator permissions will be required to add and remove notification users from the policies. If you send the notifications to a distribution or security group, you will be able to delegate the management of the group membership to an owner who does not have Teams administration permissions such as the manager of the Corporate Security Department.
- You can edit a policy by clicking on it then the “Edit” button:
Configuration Notes for Teams Emergency Policies
- The number of notification entities for the Teams Emergency Calling Policies within your firm will have bearing on your design
- The number of Teams Emergency Calling and Emergency Routing Policies you need to configure will probably be different. Teams Emergency Calling Policies are applicable to both Teams Calling Plan and Teams Direct Routing customers. Teams Emergency Routing Policies are only applicable to Teams Direct Routing installations
- The number of Teams Direct Routing SBCs will likely affect the number of Emergency Call Routing Policies that need to be created
- The number of Teams Emergency Call Routing Policies you need will impact your design for Tenant Network Sites. If you have one (1) Teams Direct Routing SBC, you should be able to use the “Global” Teams Emergency Call Routing Policy and will not need to leverage Tenant Network Sites to assign these
Kari’s Law went into effect on February 16, 2020 and applies to all MLTS installed on or after that date
The law includes the prohibition from requiring users to dial anything other than 911 on an MLTS to reach emergency services. This is addressed automatically for Calling Plan users. While this can be handled by an Online Voice Routing Policy for Direct Routing users, using Emergency Call Routing policies is the better option
There is also a requirement to notify an internal resource when a user places an emergency services call. Emergency Calling Policies must be configured for both Calling Plan and Direct Routing installations to ensure compliance
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