John Miller / / Categories: Best Practices, Cloud PBX, Microsoft, Teams, Microsoft 365

Planning Emergency Calling for Microsoft Teams

Introduction:

Routing emergency calls to the appropriate 911 Public Safety Answering Point (PSAP) is a legal requirement in the United States. There can be nuances when using any phone service, but this blog addresses the options and configurations in Microsoft Teams. Both architectures (Direct Routing and Calling Plans) are addressed here. See Deciding Between Direct Routing and Calling Plans (enablingtechcorp.com) for a primer if needed.

What?

For Calling Plan users, the Dynamic Emergency Calling feature is included. It is an end-to-end solution. Teams can determine an Emergency Caller’s current location and automatically pass the call and the current location information to the appropriate PSAP.

For Teams Direct Routing users, Teams can determine an Emergency Caller’s current location and pass that information to the client’s Session Border Controller (SBC). The call and the information must then be passed to an Emergency Routing Service Provider (ERSP) before it can be presented to a PSAP. It is the responsibility of the customer to engage with an ERSP of their choice. West\Intrado is an ERSP that has for many years offered products and services designed for Microsoft Lync, Skype for Business and Teams Direct Routing

Why?

Simply put, there are federal and many state laws that require businesses to comply. 

Federal Laws

Congress and the Federal Communications Commission (FCC) have  enacted laws in 2018 and 2019 that address aspects of Dynamic 911  Calling in the United States for Multi-Line Telephone Systems (MLTS):

  • Kari’s Law – Signed into law on February 16, 2018
  • RAY BAUM’s (Repack Airwaves Yielding Better Access for Users of Modern Services) Act – Enacted on August 1, 2019

Kari’s Law

  • The law applies to on-premises fixed and non-fixed devices and off-premises devices
  • Requires that the system support direct dialing of 911 without having to dial a prefix or access code. You cannot require a user to dial 9911 to make a call to Emergency Services
  • Notification Requirement:
    • Used to facilitate building entry by first responderskari
    • 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

RAY BAUM’s Act

  • This law applies to all on-premises fixed devices associated with an MLTS as of January 6, 2021. For these devices, a dispatchable location must be automatically provided to Emergency Services when a 911 call is placed.
  • The law’s coverage will be extended to on-premises non-fixed devices and off-premises devices as of January 6, 2022baum
  • For on-premises non-fixed devices, the location must be    provided automatically where technically feasible otherwise the  information can be based on end user manual update or enhanced location information. Enhanced location information refers to the use of coordinates or Geocodes (latitude and longitude)
  • Dispatchable locations must consist of the validated street address of the Emergency Services caller plus additional information to adequately identify the caller’s location such as floor, suite, apartment, etc.

State and Local Municipality Dynamic 911 Regulation

  • Twenty-four (24) States have existing laws regarding Emergency Services Calling. These rules can supersede the Federal laws if they are not inconsistent with them.
  • The specific elements of Emergency Calling that they cover vary greatly
  • Some municipalities have requirements that supersede those of the State
  • A current list of these requirements can be found on the West\Intrado website at http://images.insight.intrado.com/Web/Intrado/%7Ba2414acc-bfd2-4553-abd1-2f22ec133619%7D_200130-JB-WP-02-State-E911-Legislation-Summary.pdf
  • Following are some sample State regulations:
    • Florida
      • Provided addresses must be precise to the station level. This seems to apply to any business entity with a PBX
        • “Each PBX system installed after January 1, 2004, must be capable of providing automatic location identification to the station level.”
        • "Automatic location identification" or "ALI" means the automatic display at the Public Safety Answering Point (PSAP) of the caller's telephone number, the address or location of the telephone, and supplementary emergency services information.”
      • New York
        • The regulations apply to “public buildings” which they define as “any building belonging to the state, county, town, village, school district or any other political or civil subdivision of state or local government”
        • The regulation appears to require compliance with Kari’s Law but does not mandate the providing of any address information when making an Emergency Services call
      • North Carolina
        • Has no regulations

When?

  • Kari’s Law applies to all systems sold, leased, or installed after February 17,2020. Older systems are exempt
  • RAY BAUM’s act applies to all on-premises fixed devices associated with an MLTS as of January 6, 2021
    • The law’s coverage will be extended to on-premises non-fixed devices and off-premises devices as of January 6, 2022

Who?

  • Organizations need to determine their required compliance with laws and regulations governing emergency calls made by their employees. The legal department, compliance officer, and human resources personnel are the usual parties that will make this determination for the firm. They'll need education from IT and the vendors.
  • These personnel should consider exceeding the regulatory requirements to reduce risk and liability to the firm related to issues with their users being able to complete calls to Emergency Services while providing an appropriate dispatchable location. Providing the street address of a sixty (60) story building to the PSAP could be legally construed as not having provided an “appropriate dispatchable location.”
  • Once the requirements for Emergency Services calling have been established by the Company’s legal and compliance personnel, it becomes the responsibility of the technical personnel to implement these policies.
  • The technical personnel must determine whether their existing telephony and network infrastructure can support the implementation of these policies. They will have to determine the level of remediation that will be needed if they do not. For example, how do you determine if the caller is calling from an internal location? Or if it is determined that a Floor number should be included in the dispatchable location, how can the floor be derived based on the caller’s subnet, connected wireless access point, connected network switch or port on a switch?

How?

Microsoft Teams includes configurations to help an organization comply with Kari’s Law, the RAY BAUM Act, and State and Municipal regulations.

Kari’s Law

  • For Microsoft Teams Calling Plan and Direct Routing users, Teams Calling Policies will send notifications to corporate resources when a user makes an Emergency Services call.
  • By leveraging Teams Trusted IPs, Tenant Network Regions, Tenant Network Sites and Tenant Network Subnets, location specific Calling Policies can be created. The use case would be to send a notification to a building’s Security Desk rather than the Corporate Security Desk when a user in that building places an Emergency Services call.

RAY BAUM’s Act

Microsoft Teams Calling Plan Users

  • All Calling Plan users are assigned a “default” emergency address location. This is also referred to as a user’s “address of record”
  • Teams Trusted IP addresses, Tenant Emergency Addresses, Tenant Emergency Locations\Places and Teams Location Information System (LIS) database must be configured to provide the user’s current location to the PSAP

Internal Network Callers

  • For calls made by users on a Company’s internal networks, Microsoft Teams will automatically route Emergency calls to a PSAP based on the user’s current location. Teams will also provide the PSAP with the caller’s dispatchable location

External Network Callers and Callers for whom a Current Location cannot be Determined

  • Calls made from users connected to external networks or for whom a current location cannot be determined will be routed to an Emergency Call Response Center (ECRC).
  • Teams cannot currently automatically provide a dispatchable location for a user working from home, in a hotel or connected to any other external network.
  • It is expected that Microsoft Teams will in the future be able to provide Geocodes (latitude and longitude) for the external caller’s location. This will allow Microsoft Teams to remain in compliance with the requirements of the RAY BAUM act for non-fixed off-premises devices.
  • Calls from these users are screened by a live ECRC agent. The agent will be able to see the caller’s address of record. Once the caller’s current location has been determined, the call and the current location information will be passed on to the PSAP.

Microsoft Teams Direct Routing Users

  • Teams Direct Routing Users do not have addresses of record.
  • Teams routes Emergency Services calls to the Company’s SBCs made by Teams Direct Routing users.
  • Teams does this based on the configuration of the Teams Emergency Call Routing Policies.
  • Teams Trusted IP addresses, Teams Emergency Call Routing Policies, Emergency Addresses, Emergency Locations\Places and the Teams Location Information System (LIS) database must be configured to provide the user’s current location to the ERSP and the PSAP.

Internal Network Callersambulance1

  • The dispatchable location or an Emergency Location Identification Number (ELIN) is included in the information passed from Teams to an SBC during an Emergency Services    Call for callers on a Company’s internal networks.
  • The Company routes the call and the location information or  ELIN from the SBC to the ERSP of their choice.
  • The ERSP will route the call to the appropriate PSAP based on  this information.

External Network Callers and Callers for whom a Current Location cannot be Determined

  • Teams will route these calls to the SBC without a dispatchable location or ELIN.
  • The SBC will route the call to the ERSP. A live agent at the ERSP will answer the call and ask the caller for their current physical location.
  • The agent will route the call to the appropriate PSAP based on this information.

Key Points for Microsoft Teams Emergency Calling

  1. It is the client’s responsibility to comply with all laws and regulations regarding Emergency Calling from a Company provided Multi Line Telephone System (MLTS) telephone system.
  2. The client should confer with their in-house counsel, Compliance Officer and Human Resources department on the requirements for Company level Emergency Calling policies, definition of dispatchable locations and related business practices. These personnel may create corporate policies that exceed the Federal or State definitions of appropriate dispatchable locations to provide additional legal and liability protection for the organization.
  3. Documentation should be created and maintained for all these Microsoft Teams elements related to Dynamic Emergency Calling:

Teams Emergency Addresses                                               Teams Emergency Locations\Places
Teams Emergency Calling Poicies                                        Teams Emergency Call Routing Policies
Teams Trusted IP Addresses                                                 Teams Network Regions
Teams Network Sites                                                              Teams Network Subnets
LIS Database Subnets                                                             LIS Database Wireless Access Points
LIS Database Switches                                                            LIS Database Ports

  1. Clear instructions on how to make calls to Emergency Services using the Corporate Telephony equipment must be provided to the Company’s users.
  2. An organization's Corporate Counsel, Compliance Office or Human Resources department should decide on whether the users must acknowledge receipt of the instructions for making calls to Emergency Services using the organization's equipment.
  3. The information configured by the client to provide Emergency Calling services to its users must be accurate. At all times, the client’s correct current location information must be provided to the PSAP and ERSP.
  4. The client should test the Emergency Services Call Flow on a regular basis.

This is the first in a series of blogs on emergency calling. Register for our blog updates or start reading the implementation guides

 

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