Ray Baum’s Act Recap:
Other articles have unpacked the significance of the 911 Telecommunications Laws Ray Baum’s Act and Kari’s Law. The purpose of this page is to break-down the requirements in detail and to provide a quick look at what existing hotel PBX and corresponding PSTN connections are compliant and to what extent.
Ray Baum’s Act Compliance Requirements:
Communications systems installed in hotels after February 16, 2020 must be compliant with Kari’s Law, and after January 6, 2021 for RAY BAUM’s Act.
As such, when upgrading or replacing a hotel’s voice solution, confirm the vendor certifies the solution as compliant. The full FCC Ray Baum’s Act guidelines can be found on their website, but we will provide a brief summary below.
The following tables summarize the requirements of each of the new laws. These are summarized in stages for the Ray Baum’s Act, as that is how that law splits compliance:
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Ray Baum’s Act Requirement 1
Enable caller to directly dial 911 without the use of any prefix or access code.
Why Kari’s Law?
Prior to Kari’s Law, it was common practice in hotel phone system deployment to require the caller to dial 9 or a similar digit to go out of the hotel and even to dial 911. Because of this, many 911 calls failed to connect, causing unnecessary complications and even death.
Likewise, legacy hotel phone systems required the caller to dial exactly 9-1-1 with no other variation. This has also been corrected such that 9-9-1-1 , 9-1-1-1 and other iterations direct the call to 911.
Ray Baum’s Act Requirement 5
Provide for the PSAP to reach the 911 caller directly
Callback number must not be answered by an IVR or automated attendant
Ray Baum’s Act Requirement 2
Contemporaneously notify a central location on-site or off-site of the 911 call where someone is likely to see or hear it
Notification must not delay the call to 911. This should include at minimum: The fact that a 911 call has been made , A valid callback number and The same information about the caller’s location that was provided to the PSAP, unless it’s not technically feasible.
Ray Baum’s Act Requirement 6
Provide redefined automated dispatchable location to the PSAP with the 911 call from on- premise fixed devices
Dispatchable location must be the validated civic address of the calling party, plus any additional information such as building, floor, room, suite or apartment number, or other similar information that’s necessary to adequately identify the location of the calling party
Ray Baum’s Act Requirement 3
If technically feasible, provide a callback number for the PSAP to reach the 911 caller directly
Callback number must not be answered by an IVR or automated attendant
Ray Baum’s Act Requirement 4
Provide dispatchable location to PSAP with 911 call
Already current law, through PS/ALI, e.g. dispatchable location must be the validated civic address of the calling party. More specific information by the RAY BAUM’s Act is not yet required.
Ray Baum’s Act Compliance Grid
Now that we know the requirements, let’s look at the various hotel phone system and hotel phone service configurations to see how your hotel stacks up and if you’re fully compliant. Get a quote for a fully compliant system here.
The various Hotel PBX solution types in use today:
- On-Premise (legacy analog, digital and TDM based systems)
- Hybrid IP
- Hosted
And the type of PSTN connection in use, which are:
- POTS lines
- T1/PRI, CAMA
- SIP Trunking
Hotel Phone System: Non-IP
This is a traditional hotel phone system like a Mitel SX200.
Hotel Phone Service PSTN Connection: POTS
Plain Old Telephone Service (POTS) refers to a phone line or traditional phone service which works through physical wires. This type of phone service enables analog voice transmission over copper pair wires.
Requirement 1 – Yes
Requirement 2 – Yes
Requirement 3 – No
Requirement 4 – Yes
Requirement 5 – No
Requirement 6 – No
It is possible for ANY Hotel Phone System to be made compliant with Kari’s Law, but not with the stricter requirements of Ray Baum’s Act.
Hotel Phone System: Non-IP5
Hotel Phone Service PSTN Connection: SIP Trunks
What is SIP Trunking? SIP Trunking is a voice over Internet Protocol (VoIP) technology and streaming media service based on the Session Initiation Protocol (SIP) by which Internet telephony service providers (ITSPs) deliver telephone services to customers. SIP Lines can enable analog phones and SIP to send and receive calls via the internet.
Requirement 1 – Yes
Requirement 2 – Yes
Requirement 3 – Yes
Requirement 4 – Yes
Requirement 5 – Yes
Requirement 6 – Yes
To be clear, you do not have to replace your legacy PBX today. Your hotel can achieve compliance by simply changing out your legacy hotel phone service provider for SIP Trunking.
Callback compliance can be achieved with the use of DID to guest rooms. This solution exposes guests to potential fraud calls from external parties such as telemarketers or fraudsters. A secure solution requires mapping between an internal calling station and a callback number used to allow the routing of a return call from the PSAP. Compliance to reqs 4, 5 and 6 require the use of a Location Information Server (LIS) to provide accurate information about the caller’s location.
Hotel Phone System: Non-IP 2
Hotel Phone Service PSTN Connection: CAMA Trunks
CAMA – Centralized Automatic Message Accounting is a special analog trunk originally developed for long-distance billing but is now mainly used for emergency call services: 911 and Enhanced 9-1-1 (E-911). CAMA trunk connects a carrier switch directly to the Selective Router (SR), a special 911 Switch that in turn connects to many PSAPs.
Requirement 1 – Yes
Requirement 2 – Yes
Requirement 3 – No
Requirement 4 – Yes
Requirement 5 – No
Requirement 6 – No
These trunks are not used often in North America hotel phone systems. Services may still be available from service providers, but are being phased out and have limitations.
Hotel Phone System: IP
IP-enabled Hotel Phone Systems are the only modern PBX sold by most manufacturers. Mitel, Phonesuite, Avaya and others have long-retired PBX models that can’t support IP. The reason is because phone lines are now IP standard, such that all major carriers no longer sell TDM systems like PRI and TI.
What is TDM? Time-division multiplexing (TDM) is a method of transmitting and receiving independent signals over a common signal path by means of synchronized switches at each end of the transmission line so that each signal appears on the line only a fraction of time in an alternating pattern. A TDM phone technology is based on electrical circuits that are physically switched on the public switched telephone network (PTSN).
Hotel Phone Service PSTN Connection: POTS
Requirement 1 – Yes
Requirement 2 – Yes
Requirement 3 – No
Requirement 4 – Yes
Requirement 5 – No
Requirement 6 – No
Again, the PBX (IP or Non-IP) is not the issue for Ray Baum’s Act. The only way forward is to replace your existing PRI/T1 phone service with SIP Trunking for your hotel.
Hotel Phone System: Non-IP3
Hotel Phone Service PSTN Connection: T1
What is a T1? T1 Line are reserved circuits that work over copper or fiber optic cables that can deliver 24 channels of voice, data or video traffic. Each channel is capable of a maximum speed of 64Kbs. That means you can expect T1 to carry data at 1.5 Mbps (upload and download).
Requirement 1 – Yes
Requirement 2 – Yes
Requirement 3 – Yes
Requirement 4 – Yes
Requirement 5 – No
Requirement 6 – No
Callback compliance can be achieved with the use of Direct Inward Dialing (DID) to guest rooms. This solution exposes guests to potential fraud calls from external parties such as telemarketers or fraudsters.
Hotel Phone System: IP2
Hotel Phone Service PSTN Connection: T1/PRI
Requirement 1 – Yes
Requirement 2 – Yes
Requirement 3 – Yes
Requirement 4 – Yes
Requirement 5 – No
Requirement 6 – No
Callback compliance can be achieved with the use of DID to guest rooms. This solution exposes guests to potential fraud calls from external parties such as telemarketers or fraudsters.
Hotel Phone System: Non-IP4
Hotel Phone Service PSTN Connection: PRI
What is a PRI? A PRI – or Primary Rate Interface – is an end-to-end, digital telecommunications connection that allows for 23 concurrent transmissions of voice, data, or video traffic between the network and the user. The PRI line, or circuit, is a physical piece of equipment. vs. PRI technology has been around since the 1980s.
Requirement 1 – Yes
Requirement 2 – Yes
Requirement 3 – Yes
Requirement 4 – Yes
Requirement 5 – No
Requirement 6 – No
Callback compliance can be achieved with the use of DID to guest rooms. This solution exposes guests to potential fraud calls from external parties such as telemarketers or fraudsters.
Hotel Phone System: On-Premise or Hosted with IP
Hotel Phone Service PSTN Connection: SIP Trunks
Requirement 1 – Yes
Requirement 2 – Yes
Requirement 3 – Yes
Requirement 4 – Yes
Requirement 5 – Yes
Requirement 6 – Yes
Callback compliance can be achieved with the use of DID to guest rooms. This solution exposes guests to potential fraud calls from external parties such as telemarketers or fraudsters. A more secure solution requires the use of different technology to maintain mapping between an internal calling station and a callback number used to allow the routing of a return call from the PSAP. Compliance to reqs 4, 5 and 6 require use of LIS to provide accurate information about the caller’s location.
Jet Hotel Solutions has 25 years of experience in providing consulting for New Build construction and Renovations in Guest-Facing and infrastructure technology within Hospitality. Schedule a call or contact us to learn more.