Remote Workers and RAY BAUM’s Act: A Perfect Storm

By now, everyone should be familiar with rapidly deploying technologies that support pandemic remote work initiatives and have most likely heard of Kari’s law and RAY BAUM’s Act E-911 requirements. As mentioned in my previous post, “A Tale of 3 Approaches to Supporting Remote Workers,” I outlined some of the ways organizations rapidly deployed technology supports workers at home. Here, I’ll explain the impact that RAY BAUM’s Act phases will have on the remote work environment.

 

Now that the dust has settled, organizations are making strategic plans for technology replacement by re-evaluating communication, collaboration, and contact center technologies. What many may not be aware of, however, is that phase II of the RAY BAUM’s Act involving mobile requirements will take effect on Jan 6, 2022.

 

Phase I of RAY BAUM’s Act applied to fixed devices, but Phase II applies to non-fixed and off-premises devices. These include home workers on company-provided communications devices (be they hard-phone or softphones) on a PC, laptop, or mobile device. Phase II also includes “hoteling” (short-term provision of office space) and other non-fixed communications on customer premises.

 

Providing location information for non-fixed devices is tricky because several components of E-911 calls are impacted. Most people think identifying the location of the device is the most challenging aspect of conforming to requirements, but an equally, if not more challenging component is ensuring the 911 call reaches the correct Public Safety Answering Point (PSAP).

 

The rapid deployment of remote working technologies, combined with the impending RAY BAUM’s Act phase II requirements, have created a rapidly approaching perfect storm. Consider the example of an employee using a “softphone” (UC client on a PC or laptop) at home. While this worker uses their softphone at home, calls made to and from the device terminate at a central location and transport as data packets between the core system and the softphone.

 

If the worker uses their softphone to dial 911, the call goes to the PSAP associated with the central location, rather than the PSAP near their home. PSAPs have direct communication channels with local dispatch in their regions. Sending a call to the wrong PSAP substantially delays reaching the appropriate local lifesaving resources, because the PSAP near corporate headquarters may not have a direct link to the dispatch center near the employee’s home.

 

While many cloud and premises-based UC providers offer a solution for fixed devices today by assigning a dispatchable location in the user profiles, the location only applies when the employee stays put. Once this employee logs into the device from someplace different, the address in their user profile is no longer accurate. Premises-based solutions can offer a dispatchable location for fixed devices, but complexities arise when end users can move them. Take an employee on a corporate campus for example who unplugs a physical device in building A, then walks to building B and plugs it back in using their laptop-based softphone connected over Wi-Fi from a conference room or cafeteria. The dispatchable location in their user profile indicates the incorrect building.

 

Keep in mind that in some cases the unified communications and collaboration (UCC) provider’s solution may work for fixed telephony users located in a single building, but most organizations with complex environments will require a third-party solution to meet requirements. That is (at least) until UCC and contact center providers develop more sophisticated integrated solutions.

 

Many organizations assume cloud UC and contact center solutions conform to E-911 laws. That usually isn’t the case, because cloud providers often defer compliance to the end user organization with language such as, “The solution doesn’t natively support E-911; emergency services should be connected using a mobile or fixed-line telephone service; or as a backup, you should strongly consider obtaining a PSTN connection from the local exchange carrier or similar provider.”

 

Complex requirements, including the ability to continuously update user dispatchable location and PSAP connectivity in real-time, drive both capital and operating costs throughout the solution lifecycle. These costs can often be overlooked during the planning and budget phase, but represent a significant investment. What this means for organizations planning to implement new UCC solutions, enhance, or expand work from home efforts, is that the RAY BAUM’s Act mobile compliance must be incorporated into planning and budget phases to avoid unexpected costs after the budget has been set.

---