If your practice or office runs a multi-line phone system, two federal laws govern how it must handle 911. Kari's Law requires that anyone can dial 911 directly — with no prefix such as "9" — and that the system notify someone when a 911 call is placed. Section 506 of RAY BAUM'S Act requires that a "dispatchable location" (a street address plus detail such as room or floor) be conveyed with the call. The FCC adopted rules implementing both in August 2019, and those rules apply to cloud and VoIP phone systems, not just legacy PBXs. If you migrated to a hosted phone system and never revisited your 911 configuration, this article is for you.
Kari's Law: direct 911 dialing and notification
Kari's Law is named for Kari Hunt, who was killed in a motel room in Marshall, Texas in 2013. Her nine-year-old daughter tried four times to call 911 from the room phone. The calls never went through, because the motel's phone system required dialing "9" for an outside line first. Congress enacted Kari's Law in 2018, and per the FCC the requirements took effect on February 16, 2020.
Two obligations sit at the center of the law:
- Direct dialing. A user must be able to dial 911 without entering any prefix or access code. Manufacturers and vendors must pre-configure multi-line telephone systems (MLTS) to support this, and installers, managers, and operators must ensure the system as actually deployed supports it.
- Notification. When a 911 call is placed, the system must be configured to notify a central location — on site or off site — where someone is likely to see or hear the notification. The purpose is to get a human to the door to meet first responders.
The FCC's rules are forward-looking: they apply to MLTS manufactured, imported, offered for first sale or lease, first sold or leased, or installed after February 16, 2020. In practice, almost any cloud phone system a practice bought or re-provisioned in recent years falls inside that window.
RAY BAUM'S Act: dispatchable location
Direct dialing gets the call out. Dispatchable location gets responders to the right door. Under Section 506 of RAY BAUM'S Act, the FCC adopted rules to ensure that dispatchable location is conveyed with 911 calls to dispatch centers regardless of the technology platform used. The FCC describes dispatchable location as the street address of the caller plus additional information — such as room number and floor number — necessary to identify the caller's location for first responders.
That "additional information" is where most VoIP deployments fall short. A single street address for a three-story medical office building tells a paramedic almost nothing useful. The dispatchable-location compliance dates phased in by system category (fixed devices versus non-fixed devices, and interconnected VoIP separately), so check the FCC's current dispatchable location guidance for the category your system falls into rather than assuming one date covers everything you own.
Does my phone system count as an MLTS?
An MLTS is, broadly, a system serving multiple telephones within a building or campus — the category the FCC associates with enterprises such as office buildings, campuses, and hotels. A clinic with a hosted PBX, a set of desk phones, and a softphone app on staff laptops sits squarely inside it. The delivery mechanism does not exempt you: on-premise PBX, hosted PBX, SIP trunking, and fully cloud platforms are all in scope.
Separately, if you buy interconnected VoIP — VoIP that can place calls to and receive calls from the regular phone network — the FCC places its own E911 obligations on the provider. Per the FCC, interconnected VoIP providers must automatically provide 911 as a standard, mandatory feature that customers cannot opt out of; obtain the customer's physical location before service activation and provide an easy way to update it; transmit all 911 calls along with a callback number and the registered physical location to the appropriate 911 call center; disclose any limitations of the 911 service; and obtain the customer's affirmative acknowledgement that they understand those limitations.
| Party | Responsibility |
|---|---|
| MLTS manufacturer / vendor | Pre-configure the system to support direct 911 dialing |
| MLTS installer / manager / operator (you) | Ensure the deployed system actually supports direct dialing and notification |
| Interconnected VoIP provider | Non-optional 911; collect, maintain, and transmit registered location and callback number; disclose limitations |
| The practice | Keep registered locations accurate; configure notification recipients; test after every change |
Why VoIP makes this harder than landlines
A copper line is bound to a physical address by definition. A VoIP extension is not. The FCC's own consumer guidance warns that portable interconnected VoIP can be used from virtually any internet connection, which makes locating a 911 caller genuinely difficult. Its stated risks: the call may not reach the 911 center serving the caller's current location, it may not automatically transmit the caller's number or location, and VoIP may not work at all during a power outage or internet failure.
For a medical practice, three VoIP-specific failure modes matter most:
- The roaming softphone. A billing coordinator working from home dials 911 from the practice softphone. Unless that user's registered location has been updated, responders may be sent to the clinic.
- The stale registered address. The practice takes over the suite next door, moves phones around, and never updates the address on file with the carrier.
- The satellite office on one trunk. Several sites share a main number and a single registered address, so every 911 call appears to originate from headquarters.
An E911 configuration checklist
- Confirm 911 dials directly from every device — desk phone, conference phone, softphone, and mobile app. No "9" prefix, no access code.
- Register a dispatchable location for each physical site and, where the platform supports it, each floor, suite, or wing.
- Enable 911 notification and route it to people who are physically present during business hours.
- Set a policy — and, if the platform supports it, a login-time prompt — requiring remote and softphone users to confirm or update their location when they connect from a new place.
- Name the person who updates registered addresses when the practice moves, expands, or opens a location, and put it on the move checklist.
- Re-test after any carrier change, number port, or phone-system upgrade.
- Keep a fallback path for emergencies — a mobile phone or battery-backed line — for when power or internet is down.
Common E911 mistakes in clinics
- Assuming the cloud provider "handles 911" and never checking what address is actually on file.
- Sending 911 notifications to an unmonitored shared inbox.
- Treating a multi-suite or multi-floor building as one location.
- Leaving the legacy "dial 9 first" instruction on phone labels, in staff onboarding materials, and in the front-desk binder.
- Forgetting that after-hours and answering-service routing does not change 911 — the handset itself still has to dial out directly.
What to ask your VoIP provider
- How do we register and update a dispatchable location per site, floor, and suite — and can our staff do it without opening a ticket?
- What 911 notification channels do you support, and how do we set the recipients?
- How does the platform handle a 911 call from a softphone or mobile app on an unfamiliar network?
- Is a registered location associated with every DID and extension, or only with our main number?
- What happens to 911 if our internet connection fails?
- Can you provide written documentation of how your platform supports the FCC's Kari's Law and RAY BAUM'S Act requirements, so we can keep it with our compliance records?
E911 rarely comes up in a phone-system RFP and almost never comes up in a demo. It comes up on the worst day the practice has. Fifteen minutes of configuration and one coordinated test call is the entire cost of getting it right.
Common questions
Does Kari's Law apply to cloud and VoIP phone systems?
Yes. The FCC's rules apply to multi-line telephone systems regardless of the underlying technology, so a hosted PBX or cloud platform serving a clinic is covered.
Do we still need to dial 9 before 911?
No. The entire point of Kari's Law is that 911 must be reachable directly, without a prefix or access code. If your system still requires a 9, it is misconfigured.
What is a dispatchable location?
Per the FCC, it is the street address of the caller plus additional information such as room number and floor number, needed for first responders to actually find the caller.
What happens if a staff member dials 911 from a softphone at home?
Unless that user's registered location has been updated, the call can be delivered with the clinic's address attached. Set a policy requiring remote users to confirm their location, and tell staff to use a mobile phone for personal emergencies at home.