RAY BAUM'S Act and MLTS: Dispatchable Location for Hotels Explained

Section 506 of RAY BAUM'S Act led the FCC to require a "dispatchable location" with 911 calls: the validated street address plus the room, floor or other detail responders need. For hotels, senior living communities and casino resorts, that rule applies through their multi-line telephone system (MLTS). Fixed phones had to send it automatically from January 6, 2021. Softphones, tablets and other devices that move had to follow from January 6, 2022, where technically feasible. Getting it right is mostly about the location data behind each extension.

What is an MLTS?

MLTS stands for multi-line telephone system. Federal rules define it broadly: the control equipment, phones, software and add-on systems that let many extensions share outside lines. The definition names PBX, key and hybrid systems, Centrex and VoIP. It covers network-based (hosted) systems as well as equipment on the premises, and it applies to businesses, non-profits and government alike.

In practice, if your property has a PBX in a closet, a hosted or cloud PBX, or any setup where rooms and departments have extensions, you run an MLTS. The FCC names hotels, office buildings and campuses as typical places where they're installed.

What RAY BAUM'S Act requires

RAY BAUM'S Act became law in 2018. Section 506 directed the FCC to consider rules so that a dispatchable location goes with 911 calls, whatever technology places the call. The FCC adopted those rules on August 1, 2019, in the same order that put Kari's Law into effect. Under the rules, whoever installs an MLTS may only install one that can be programmed with and send a dispatchable location, and whoever manages or operates it must make sure it's configured to do so.

The FCC defines dispatchable location as the validated street address of the caller plus additional information, such as suite, apartment or similar details, needed to adequately identify where the caller is. For a hotel, the "similar details" are the building, floor and room.

For multi-line systems, the rules depend on the kind of device:

• Fixed devices (a wired room or desk phone that stays put): automated dispatchable location by January 6, 2021.
• Non-fixed devices on premises (softphones, tablets, handsets used around the property): automated dispatchable location by January 6, 2022 if technically feasible. Otherwise a location the user updates manually, or alternative location information good enough to identify the address and approximate in-building location, including the floor in large buildings.
• Off-premises devices (a staff softphone used at home): automated dispatchable location by January 6, 2022 if technically feasible. Otherwise a manually updated location or enhanced location information, which can be coordinate-based.

Both dates have passed, so these are current requirements. The location rules sit alongside Kari's Law, which requires direct 911 dialing with no prefix and an on-site notification when 911 is called. Our Kari's Law guide covers that half.

The same Section 506 rules also cover fixed telephone service, interconnected VoIP and internet-based relay services, each with its own requirements. Wireless carriers fall under separate FCC location-accuracy rules.

How dispatchable location works in a hotel

The phone system doesn't "know" where a room is. Someone has to tell it. A working setup has three parts:

• A location for every extension. Each room, back-office phone and lobby phone is tied to a validated street address plus building, floor and room.
• A way to keep moving devices current. Softphones, tablets and staff mobiles need their location updated automatically, for example from the Wi-Fi access point or network switch they connect through, or the user needs a simple way to update it.
• Delivery to the 911 center. When 911 is dialed, the location goes with the call through your carrier or E911 service provider. With legacy E911, the 911 center looks it up from the callback number. With NG911, the location can travel as data with the call itself.

Writing locations responders can use

The address is the easy part. The detail that gets responders to the right door is what usually goes wrong. A few habits help:

• Name buildings and towers the way staff and signs do. "South Tower, Floor 11, Room 1104" beats "Bldg 2 Rm 1104".
• Label shared and back-of-house spaces. Pool deck, fitness center, kitchen, loading dock, parking levels and, at casino resorts, gaming floors and cage areas. A 911 call from a house phone in one of these places needs a location staff will recognize.
• Use the entrance responders should come to where it differs from the street address. For a resort with several buildings, that can save minutes.
• Re-check after any change. Renovations, room renumbering, a new wing or moving phones between rooms all break location data quietly.

Senior living and multi-building properties

Senior living communities and campuses add their own challenges. Residents may not be able to say where they are, apartments can be spread across several buildings, and the front desk may not be staffed overnight. Make sure every apartment's location names the building, floor and unit, and that 911 notifications reach staff who are on shift. We cover this in more depth in E911 for hotels and senior living, and on our senior living and casino resort pages.

A dispatchable location checklist

• Every phone and device on the system maps to a validated address plus building, floor and room or area.
• Softphones, tablets and staff mobiles update their location automatically, or users have an easy way to do it.
• Back-of-house, outdoor and shared spaces have names staff recognize.
• Location data is reviewed after renovations, renumbering and device moves.
• 911 test calls are run on a schedule, coordinated with your local 911 center, from each type of device.
• The on-site notification (Kari's Law) shows the same location and a callback number.
• 911 still works, with location, if the internet connection to a cloud phone system goes down.

What to ask an E911 service provider

Whether location comes from your phone vendor, your carrier or a separate E911 provider, ask:

• How are locations entered and validated, and who maintains them?
• How do softphones, tablets and mobile devices get an automatic location on property?
• What does the 911 center actually receive? Ask to see a test call.
• What does the on-site notification look like, and who receives it (desk, security, staff mobiles)?
• Does it work with our trunks (T1, PRI or SIP) and our PBX?
• What happens to 911 during an internet or power outage?
• Is NG911 supported where our 911 centers have upgraded?

How HotelGenie handles it

HotelGenie E911 / NG911 sends the caller's room-level location to the 911 center, alerts staff right away by SMS, email and voice, and lets responders call the caller back. It works with phone systems on T1, PRI or SIP trunks, supports location labels staff recognize, and offers optional 911 call recording. With PhoneGenie Edge on site, 911 goes out a local line at the property even if the internet drops. For incidents staff need to raise themselves, there's Emergency Alert.

This article is general information, not legal advice. Confirm your property's obligations with counsel and your local 911 authority.

RAY BAUM'S Act and MLTS questions

Sources

Regulatory details are from the FCC and 911.gov. Rules can change, so check the current text before making compliance decisions.

• FCC: Multi-line Telephone Systems – Kari's Law and RAY BAUM'S Act 911 Direct Dialing, Notification, and Dispatchable Location Requirements
• FCC: Dispatchable Location for 911 Calls
• eCFR: 47 CFR Part 9, Subpart F (Multi-line Telephone Systems)
• 911.gov: Kari's Law and RAY BAUM'S Act