Is Your Hotel Fully Compliant with the RAY BAUM's Act?

Disclaimer: This article does not constitute legal advice; it is intended for general informational purposes only.

Can first responders reach your hotel guests when 911 is called? If the answer is no, or it’s not as easy as it could be, then your hotel may be breaking federal law.

On January 6, 2022, the final requirement of RAY BAUM’s Act came into effect, as set forth by the FCC. This means that any Multi-Line Telephone System (“MLTS”), including hotels and resorts, that does not comply with all aspects of RAY BAUM’s Act and Kari’s Law are not consistent with emergency call planning best practices. Despite this, research from Metrigy’s Workplace Collaboration report found that only 57% of enterprises today are compliant with RAY BAUM’s Act. What does this mean for the hotels and resorts specifically?

Kari’s Law, as many of you know, originated in the hospitality industry. In 2013, a  woman named Kari Hunt was tragically killed in a hotel room in Texas, and her daughter was unable to reach emergency assistance because the hotel’s phone system required a prefix to call outside the hotel. The law acts against preventable losses of life by removing barriers to reaching authorities, alerting relevant personnel such as front desk and security when a 911 call is placed, and providing a callback number.

Another aspect of Kari’s Law- notable in particular for hotels- is that a 911 call must route directly to the serving Public Safety Access Point (PSAP). Hotels have historically had their security centers or front desk intercept 911 calls before forwarding them to the PSAP. At the heart of Kari’s Law is the idea that any roadblock between dialing 911 and reaching emergency responders is unlawful. That said, the security center or front desk is required to receive notification that 911 has been dialed, and may (optionally) receive a one-way real-time audio feed from the call, as well as the ability to “barge-in” to the call, depending on equipment capabilities. 

Texas 9-1-1 authorities have stated that Kari’s Law and the circumstance behind its enactment demonstrate that “it is simply unreasonable to expect 9-1-1 callers to know or remember when they are required to do something differently during a 9-1-1 call based on their particular device or location”. [FCC 19-76]

This is especially salient in hotels: the hospitality industry must be hospitable after all, even in the event of an emergency.

RAY BAUM’s Act requires large enterprises, which includes hotels and resorts, to fashion their MLTS so that every 911 call delivers a “dispatchable location”. RAY BAUM’S Act defines “dispatchable location” as “the street address of the calling party, and additional information such as room number, floor number, or similar information necessary to adequately identify the location of the calling party.”

For hotels, the dispatchable location needs to contain adequate building, floor and room-level information to direct first responders to the location of the caller. The objective of the regulation is to ensure that 911 dispatchers have the detailed information needed to direct first responders to the caller as quickly as possible. 

There are challenges associated with supporting each hotel-specific aspect of these regulations, which be summarized by the following steps:

1.  Remove any prefix to allow direct 911-dialing. This “one and done” provisioning of dialing patterns (typically both the digits “9-1-1” and digits “1-9-1-1”) is relatively simple to configure on most MLTS systems
2. Route 911 calls directly to public safety and send notifications to the front desk or security so that appropriate preparation for the arrival of First Responders can take place. This requires (1) that the hotel establishes a policy and training for staff around how to respond to the reception of an emergency notification and (2) appropriate provisioning for the generation and delivery of the notification. Most modern MLTS systems have built-in notifications such as screen pop-up, text message, e-mail or a “ring and announce” capabilities that simply need to be enabled.
3. Provision the dispatchable location for each guest room. Depending on the phone system in place, provisioning dispatchable locations can be more complex and sometimes requires the inclusion of services from MLTS-specific vendors. That is, services exist that can augment most MLTS systems, such as Cisco UCM, Avaya, MiTel/ShoreTel, and many other brands, to bring the hotel MLTS system as a whole into compliance...

Complying with RAY BAUM’s Act can be challenging, - which is representative of the fact that barely half of all enterprises are reporting full compliance to this safety measure; along with time, budget, competing priorities, and oftentimes lack of education.

That said, the legal risks of non-compliance are substantial, including potential financial liability. In the case of Kari Hunt, the family received a settlement of over $40 million. Not to mention the possibility of negative PR, which could impart hidden costs and damage a hotel’s reputation of prioritizing their guests’ safety.

Setting legal compliance aside; with the potential safety of guests and staff at stake, it is imperative that hotel administrations understand and implement these safeguards. An emergency can occur at any time.  Delivery of dispatchable location assists first responders in the fastest delivery of emergency aid. First responders have often shared how critical it is to know where someone is specifically located when the caller is in crisis or unable to communicate effectively. Ultimately, should a circumstance be so urgent as to require an entrance to be breached, first responders must know they’re entering the right location.

After supporting countless enterprises, including hotels through this practice, we can offer some advice on getting started.

1. Consult with your legal counsel about regulations that may impact your hotel. A legal team can translate regulations into actionable items for your hotel or resort.
2. Get educated on the regulatory landscape. Some hotel chains operate internationally – although here we have reviewed the United States’ regulations, other countries have regulations that vary widely. Further, within the US, there can be additional regional or state-level regulations that are more restrictive than the national mandate.
3. Take stock of your hotel’s current phone system. Hotels utilize a wide range of communication tools. From on-premises telephony systems, (such as Cisco and Avaya equipment), to cloud-native (unified communications or cloud-based voice platform or other type of phone system), or some hybrid mix of the two, the RAY BAUM’s-compliant solution will look different. 
4. Leverage partners that will help you through the process.  Did your telephony provider participate directly in the regulatory process that created these rules at the FCC? Do they have global regulatory experience? Are they a National Operator in different countries?