By January 6th, 2022, organizations using Teams Phone System must make changes to comply with RAY BAUM’s Act. The law requires the org to accurately provide the physical address of their employees when they call 911 from Teams, no matter their location.
This is deadline number two of the act, specifically aimed at remote and nomadic workers on Teams mobile and desktop apps (softphones). Act I should’ve been completed by January 6th, 2021. At that time, the law required that an organization provide accurate “dispatchable location” information for fixed VoIP (hard phones) inside the organization’s premises. Our colleague John Miller has written extensively on how to configure e911 in Teams for enterprise locations.
Now it’s time to solve the harder problem, nomadic and Work from Home (WFH) employees.
Organizations will need to:
- Make some configuration changes in the Microsoft Teams Admin Center. These changes are being finalized by Microsoft and Enabling will detail them as soon as possible.
- Test the changes.
- Communicate to employees about how their experience will be different after the change.
- Confirm (when using Direct Routing) the telecom provider can read the SIP setup message to route the call to the correct Public Safety Answering Point (PSAP) based on the location info within the header
More detail on each step is provided next, and some important caveats and advice.
- Configuration Changes That will be Required.
Microsoft is finishing their testing and user experience. They’ll then provide details of the configuration changes that are needed for the WFH scenario, and Enabling’s blog will provide details when available.
You can test by calling 933. A recording will read back to you the current location of the caller. That’s the same address the PSAP would receive from Teams if you were to dial 911.
- Communicate to employees.
The day after the change is made, people logging in from home or other locations that aren’t pre-defined in the Teams Location Information Service database will received a pop up prompting them for their address. If your Teams admin has configured Teams for RAY BAUM’s 2021 rule for fixed VoIP phones in corporate buildings, then they should have no extra prompts while on-premises.
We will have details about the experience once the capability exists in our tenant. Our current understanding is that users will receive a pop-up, start typing in their address, be prompted to auto-fill, and then confirm. If they don’t confirm or if the address is unknown, then it’s our understanding that their 911 calls will be screened in a national 911 call center, where an operator will ask the caller their location and then route them to the local PSAP.
4. Confirm with teleco provider (when using Direct Routing)
When the user confirms or corrects their address, MSFT will be ready to send that location in the setup message of 911 calls. When using Calling Plans, Microsoft will be sending it on, so that the call gets routed to the correct PSAP. However, if Direct Routing is being used, not all telecom providers can parse that location information out to properly route the call. There are some that can (i.e. Bandwidth.com, IntelePeer) but for those who cannot, there is a gap in compliance. The telecom either needs to make provisions to comply, or the customer needs to seek out a telecom provider that can. Intrado provides separate SIP trunks for e911 calls only to help organizations without an adequate currect telecom provider.
- The feature isn’t in public preview yet. General Availability will be cutting it close to 1/6/22, so prepare to prepare now.
- Users must put in their accurate location so that the first responders know where to find them. Some privacy advocates may feel they shouldn’t provide an actual address. If they try to enter 123 Main Street, Teams checks the national 911 location database, and won’t verify it.
- However, if they fat finger the address with a real address i.e. 123 South State instead of 123 North State, they’ll be verified and logged in. But when they call 911 first responders will be dispatched to the other side of town!
- The 911 location lookup is done in real-time by the Teams service in the cloud. If your Internet connection is down, then 911 won’t work (and neither will phones or softphones). Users should know an alternate (or primary) way to call 911 (i.e. their smartphone).
- The user will see this prompt anytime they’re logging in to Teams from a new/unknown IP address (i.e. hotels, coffee shops, etc.). If Teams recognizes the IP address that they’re logging into (i.e. on a corporate network that is recognized in the Location Information Service or while working from home from the same ISP connection), there will be no prompt.
- VPNs are tricky. For multiple reasons, Teams traffic is best split out from a VPN tunnel.
- The Operating System may know the current location via the GeoCode, in which case a user might be able to just ‘confirm’ where they are. The Teams client may pop up with an address, before the user has to type a new one from scratch. This could come a few different places (pre-programmed info in Teams, or using GeoCodes that the Operating System picks up). This is not a given, however.
- Is Microsoft responsible or is the organization? The organization is responsible, but Microsoft must make Location Information Service and screen pops available to provide dispatchable location information.
- Should I hardcode the IP addresses and physical locations of employees’ home offices into Teams? That’s up to you. That might make it less of a hassle on the user experiences the change, but it’s not scalable to do this for a large organization. Keep in mind their ISP-provided IP address may change, and the pop-up will appear at that time anyway, since it’s an unrecognized IP.
- What about older (non-Teams) systems like Skype for Business Server or an Avaya PBX? If you have an older system, which cannot provide the dispatchable location like Teams, it’s you and your legal team’s decision. Enabling suggests doing all can to protect your users.
- What is the law specifically? Details are provided by the FCC. By January 6th, 2022, non-fixed VoIP callers (softphones for remote and mobile employees) must have their location identified when they use Teams to dial 911. This requires some changes to be made in the Teams Admin Center that will soon be available. Fixed phones (organizational premises) should’ve been programmed to comply in January 2021.
- What are the penalties for non-compliance? $10,000 plus $500/day for the period of non-compliance, plus the general risk for your employees.
- Does the Federal Law overrule the state’s law(s)? No, state laws (where applicable and more stringent), are enforced.
- Is the author a lawyer, and does Enabling provide legal advice? No and no. Please consult counsel for specific questions you have about liability related to the choices above.