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Work from Home on Teams & Comply with RAY BAUM

Introduction

Configuring Microsoft Teams to comply with the part of the RAY BAUM (Repack Airwaves Yielding Better Access for Users of Modern Services) Act that went into force on January 6, 2021, was detailed in a previous article in this series: Configuring Teams to Comply with RAY BAUMs 911 Act.

For a higher-level video blog on this important topic, watch https://blog.enablingtechcorp.com/teams-911-expert-on-ray-baum-karis-law 

In this article, we will provide information on the “Work From Home (WFH)” functionality being added to the Microsoft Teams Dynamic 911 solution. WFH is intended to bring Microsoft Teams into compliance with the part of the RAY BAUM act that will come into effect on January 6, 2022.

The first part of the RAY BAUM Act went into effect on January 6, 2021 and requires that a dispatchable location be automatically provided to the Public Safety Access Point (PSAP) when an emergency services call is placed from fixed on-premises devices connected to a Multi-Line Telephone System (MLTS). 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.

The second part of the Act addresses calls made from non-fixed on-premises and all off-premises devices connected to a MLTS. Microsoft Teams has had the ability to provide dispatchable locations for non-fixed on-premises devices for a while. It did not have the ability to do so for all off-premises devices until the introduction of WFH.

When will this change occur?

  • Standard and GCC tenants: The rollout has begun and should be completed in mid-December
  • GCC High and DoD tenants: This rollout has begun and should complete in December

Is this turned on by default?

  • No, the Teams administrator must turn this on in the Team Emergency Calling Policy
  • This change can only be made currently through Teams PowerShell
  • To enable this for a single Emergency Calling Policy named “Headquarters”, run this command in a Microsoft Teams PowerShell Session: 

    Set-CsTeamsEmergencyCallingPolicy -Identity “Headquarters” -ExternalLocationLookupMode Enabled

  • To enable this for all Emergency Calling Policies, run this command:

    Get-CsTeamsEmergencyCallingPolicy | Set-CsTeamsEmergencyCallingPolicy
    -ExternalLocationLookupMode Enabled

Who will this effect?

  • This will change the user experience for:
    • Microsoft Teams users who are signed on to an endpoint that is not connected to their Corporate Network
      • Users working from home full or part time
      • Users signed into networks at airports, customer or vendor locations, libraries, coffee shops, their mom’s house, etc
      • Users using a cellular network or signed on to cellular hotspots
    • Microsoft Teams users who are signed on to an endpoint that is connected to their Corporate Network for which the Teams client was not able to derive their location based on any of the network identifiers. Put another way, a user connected to a Corporate Network location that has not been correctly setup for Microsoft Teams Dynamic 911. THIS SHOULD NEVER OCCUR, AND WOULD BE A RED FLAG... since Part 1 of RAY BAUM mandated that on-premises locations be auto-located.
    • WFH is initially supported for these clients:
      • Teams Windows Client
      • Teams Mac Client
      • Teams Mobile Client with some limitations
        • The client does not support entering addresses
        • It does not “remember” the association between addresses and network locations

What is the impact on Training, Corporate Safety, and Compliance Policies?

  • For the Work from Home capability of Teams Dynamic 911 to work, you will need to educate your users on how to use this new feature. The Teams users must know how to use this feature correctly
  • There are some “touchy” considerations when implementing this capability. It is ultimately the user’s responsibility to verify the address being provided to the PSAP by the Teams client is complete and accurate at all times
  • Corporations should consider the legal and liability ramifications of the WFH feature. If a user were to call emergency services through the Teams client with an incorrect address associated with their current location, is there any litigious exposure for the Corporation?
  • Is there exposure if the Corporation did not provide proper training on the use of WFH? If the responsibility of the user to ensure the accuracy of an address was not made clear in a Corporate handbook?
  • Enabling has asked Microsoft if there are any safeguards available such as a report that could show proper use or compliance with address verification within Teams. This article will be updated with our findings

What will the user experience be?

  • After signing in, your Teams client will send a location request to the Teams tenant backend service and will simultaneously ask the endpoint’s Operating System to provide a location
  • A location returned by Teams Dynamic 911 has precedence over one returned by the Operating System
  • The Operating System will return a location for the device if:
    • It has been able to determine the location of your machine. The Operating System will use a combination of several sources to determine your location:
      • Global Positioning System (GPS)
      • Nearby Wireless Access Points
      • Cell Towers
      • Your IP address
    • The Location Privacy Settings on a Windows endpoint are configured to allow Teams to access your location from the Operating System
      • If you do not want to grant these permissions or your IT Administrators have configured policies that don’t permit it, you will still be able to manually provide your current location to Microsoft Teams
      • If you see a message like the following, your IT Administrators are managing these policies for you:

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      • The Location Privacy Settings on your endpoint must be properly configured to pass the requested information from your Operating System to Microsoft Teams
      • There are several good articles available on how to configure these settings including Windows location service and privacy for the Windows 10 and Windows 11 Operating Systems
  • The first time Teams asks the Operating System to provide a location; you may be asked if you want to allow Teams to do so. Microsoft recommends that you provide this permission. If you do not, you will still be able to provide your location manually
  • The Operating System will return your location in the form of Geocodes. These are the latitude and longitude of the location
  • Teams will send the Geocodes to the Teams backend service. The backend service will return the best match for the Geocodes

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  • You will have the option to confirm or edit the provided address
  • Microsoft and many others working on these solutions have observed that the Geocodes retrieved from the Operating System do not always accurately reflect the current location
  • Even if the Geocodes are correct, there are problems with the public databases that match addresses to the Geocodes
  • For these reasons, addresses derived from Operating System Geocodes must be confirmed by the user. It is hoped that in the future, these confirmations will not be required

Baum rework 2

  • The user will be able to edit the suggested address as needed

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  • Once confirmed or edited, the address will be saved for the user with a reference to the current network. If the user signs on to Teams while connected to the same network, the saved address will be used as the suggested address
  • If the user confirms the suggested address, it is “classified” as a “validated address”. When a user with a “validated address” places an emergency services call, Teams will route the call to the PSAP for Calling Plan Users
  • For Direct Routing users, Teams will send the PIDF-LO (Presence Information Data Format - Location Object) information and the ELIN (Emergency Line Identification Number) for the location to the Session Border Controller (SBC)
  • Edited addresses are “classified” as “unvalidated addresses”. When a Calling Plan user makes an emergency services call, Teams will route the call to the Emergency Call Response Center (ECRC) for screening. Once the ECRC agent has acquired the caller’s address, the call will be routed to the PSAP by the agent
  • If the user does not confirm the derived address, it will be treated as an “unvalidated address”
  • The Teams backend service will not be able to provide an address for the user for any of these reasons:
    • The user did not provide permission for Microsoft Teams to get a location from the Operating System
    • The Location Privacy Settings are not configured to provide the Operating System’s location to Teams
    • The Teams backend service cannot derive any addresses for the Geocodes presented by the Operating System
  • In this case, the user will be able to manually enter their current address

Can WFH be used if an On-Premises user cannot get a Dynamic 911 Location?

  • The technical answer is “Yes” but the legal answer may be “No” or “it depends”
  • Keep in mind that the RAY BAUM Act as of January 6, 2022, specifies that a Dynamic Location should automatically be provided for all calls made from any device connected to a MLTS
  • In terms of compliance with the Act, this use case should never happen. Fixed and non-fixed devices connected to a Corporation’s on-premises networks should always get a location from Dynamic 911
  • If a user is not on a network with a network identifier that matches a Wireless Access Point, Switch Port, Switch or Subnet defined by the administrators as a Network Location, the user will be treated as an off-premises WFH user
  • The Corporation should ensure that all networks that could host Teams users and devices are properly configured for Teams Dynamic 911
  • Microsoft may be adding the ability to track this type of error and provide reporting
  • The Corporation should educate their users to report when this happens
  • Put another way, a user on a Corporate network should never see the dialogs and flows associated with the WFH functionality

Is there a way to visualize what happens when someone calls 911 for all scenarios?

This table provides a summary of the possible outcomes of a 911 call ( how the calls are handled for Calling Plan and Operator Connect users).Baum rework 4

For Direct Routing, check with your Emergency Routing Service Provider to see how they handle calls that have missing or incorrect location information.  

Summary and Disclaimers

  • Enabling is not able to provide legal advice on this matter, and encourages organizations to work with their legal teams. 
  • State laws are often more restrictive than federal laws for fixed/organizational locations. State laws haven't been specific about the Work From Home scenario yet.
  • While a Teams softphone may be an option to call 911, it's usually not the only way, and often not the best way, to reach emergency services.
  • The second part of the RAY BAUM Act will go into effect on January 6, 2022, and applies to all MLTS sold or installed after this date.
  • It requires that a dispatchable location be provided to the PSAP when a user places an emergency call from an MLTS.
  • Non-fixed on-premises and all off-premises devices are required to comply by January 6, 2022.
  • With the rollout of the Dynamic 911 WFH capability, Teams can provide dispatchable locations for all fixed and non-fixed on-premises and off-premises devices.
  • The process to configure Teams to provide these locations for WFH users is the same for Teams Calling Plan and Direct Routing users.
  • This feature will not work unless the Work From Home users are diligent about verifying their current address when using Microsoft Teams. System defaults may not be accurate.  

Our video blog outlines some of these same concepts at a higher level. 

Work with our team of Cloud Computing Consultants who have done this so many times they know all of the “minefields” to prevent missteps.

Tags: Phone System
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