Because Compliance Is More Than a Technology Problem
If your organization operates a multi-line telephone system, whether it is a traditional PBX, a cloud UCaaS platform like Zoom, Microsoft Teams, or RingCentral, or anything in between, you are subject to federal 911 regulations under Kari’s Law and RAY BAUM’S Act. Those regulations require direct 911 dialing without a prefix, accurate dispatchable location data, and real-time notification to on-site personnel when a 911 call is made.Most organizations assume that if their phone system vendor has checked those boxes, they are compliant. In practice, compliance is far more fragile than that. Technology configurations drift. Employees move. Networks change. And when an emergency happens, the gap between what your system was configured to do and what it actually does in that moment can have serious consequences.911ComplyPoint® exists to close that gap.
The Regulatory Reality
Kari’s Law and RAY BAUM’S Act are federal mandates enforced by the FCC. They apply to any organization using an MLTS, regardless of size, industry, or whether your phone system lives on-premise or in the cloud. Compliance is not optional, and the responsibility for ensuring that your system sends accurate data and operates correctly sits with your organization, not your carrier or your vendor.
The regulations require:
Direct 911 Dialing
Dispatchable Location
Centralized Notification
Users must be able to reach 911 without dialing a prefix or access code. No “dial 9 first", no restrictions.
When a 911 call is made, your system must transmit accurate location data, including street address, floor, and room or other identifying information, to the PSAP so that first responders can find the caller.
Your system must notify a central on-site location, such as a front desk, security desk, or operations center, in real time when a 911 call is placed from your premises.
The Liability Reality
When 911 systems fail, organizations face serious legal and financial exposure. Two cases illustrate what is at stake:
In the case that gave Kari’s Law its name, a Texas jury awarded $41 million to the family of Kari Hunt, whose young daughter was unable to reach 911 from a hotel phone because the system required dialing an extra digit for an outside line. The tragedy occurred before Kari’s Law was enacted, and it is exactly the scenario the law was written to prevent.
In 2022, the family of TJ Mister, a six-year-old boy who drowned at a summer camp, sued for $40 million and settled for $8 million with St. Louis County. A pool maintenance worker had called 911 from an office phone, but the improperly configured phone system routed the call to a Colorado dispatch center, where it went to voicemail before being rerouted. The delay in emergency response contributed to the tragedy, a direct consequence of a non-compliant MLTS configuration.These are not isolated incidents. Most 911-related lawsuits settle out of court under confidentiality agreements. The cases that become public record represent a fraction of the actual liability exposure organizations face when emergency communication systems fail.:
Why Vendor-Independent Certification Matters
Your phone system vendor has an interest in telling you that your system is compliant. 911ComplyPoint® has an interest in telling you the truth.As a vendor-independent program, 911ComplyPoint® has no equipment to sell, no software license to push, and no manufacturer relationship that influences our findings. Our audit evaluates your entire 911 call management environment, including technology, policies, procedures, and people, against the actual requirements of your specific PSAP and regulatory environment. We work with any platform, any carrier, and any facility configuration.That independence is why multiple county PSAPs and emergency communication centers have recommended the 911ComplyPoint® audit process to their constituents. It is also why our findings produce location data accuracy that a Minnesota ECC 9-1-1 and GIS Specialist described as producing better information for telecommunicators than 90% of the calls their county receives.
Why Technology Alone Is Not Enough
Even a correctly configured system can fall out of compliance quickly. Consider what happens in a typical year at most organizations: A significant share of employees are relocated through office redesigns. Network and telecom equipment is replaced or upgraded. New UCaaS features are deployed. Hybrid and remote workers connect from locations that were never registered in the system. Wi-Fi access points create signal overlaps that produce inaccurate floor or zone data. PSAP systems truncate location fields that exceeded character limits no one knew existed. Each of these events is an opportunity for your 911 compliance posture to degrade, silently, without any system alert or warning. 911ComplyPoint® establishes the ongoing processes and policies that keep your organization compliant as your environment evolves.
About 911ComplyPoint®
911ComplyPoint® is the vendor-independent certification program for 911 call management procedures under Kari’s Law and RAY BAUM’S Act. It was developed to address a gap that exists in nearly every organization that operates a multi-line telephone system: the gap between having a compliant technology configuration and having a compliant, sustainable emergency communications program. Technology alone does not achieve compliance. Regulations require accurate dispatchable location data, direct dialing capability, and real-time notification to on-site personnel. All three of those requirements depend on operational processes, worker policies, and ongoing maintenance, not just equipment settings. When employees move desks, when networks are reconfigured, when a new UCaaS platform is deployed, the 911 compliance picture changes. 911ComplyPoint® is built to address that reality. The program has received approval from the International Organization for Standardization to contextualize 911 emergency communication compliance within the ISO 45001 framework, reframing 911 call management as an occupational health and safety issue rather than a telecommunications checkbox. The audit process has been recommended by multiple county PSAPs and emergency communication centers, and has been recognized by 911 professionals as producing location data accuracy that exceeds the standard for the majority of calls those centers receive.
Each of the four audit modules, Address Validation and Formatting, IT Operations and Worker Policy Review, Safety Plan Integration and Centralized Notification, and PSAP Outreach and On-Site 911 Testing, is available as a stand-alone service. Combined, they constitute the full 911ComplyPoint® Audit and Certification.
About Communications Advantage, Inc.
911ComplyPoint® is a service of Communications Advantage, Inc., a vendor-independent consulting firm based in Long Beach, California. Founded by Robert Lee Harris, Communications Advantage serves enterprise clients across three practice areas: legacy telecom and contact center consulting, SaaS and licensing cost audits, and 911 compliance through 911ComplyPoint®.The firm’s vendor-independent model means clients receive objective guidance without the conflicts of interest that come with vendor-affiliated advisors. Communications Advantage has no reseller agreements, no manufacturer partnerships, and no financial incentive to recommend any particular technology solution.
To learn more about Communications Advantage and its full range of services, visit communicationsadvantage.com.
About Robert Lee Harris
Robert Lee Harris has spent more than twenty years helping enterprise organizations evaluate, deploy, and optimize communications technology. But it was a recurring pattern he kept encountering with clients, confusion about what 911 compliance actually required, and a market full of vendors offering equipment without addressing the policies, procedures, and people that determine whether an emergency call actually works, that led him to create 911ComplyPoint®.For years before the program existed, Robert and his team at Communications Advantage were helping clients work through 911 compliance on a case-by-case basis. Clients understood the regulatory obligation but struggled to translate it into sustainable practice. The technology might be configured correctly today, but employees move, networks change, and facilities evolve. Without a structured, ongoing process, compliance erodes. Robert recognized that the missing framework was already hiding in plain sight: ISO 45001, the international standard for Occupational Health and Safety Management Systems. By grounding 911 compliance within ISO 45001, 911ComplyPoint® moves organizations beyond checkbox compliance into a continuously maintained, auditable safety program. Robert is the co-chair of the NENA IP-Based MLTS Considerations Working Group, which develops vendor-neutral configuration guidance and reference architectures to assist MLTS and UCaaS system operators in achieving functional compliance with Next Generation 9-1-1 (NG9-1-1) standards. He also participates in the NENA Indoor Mapping Working Group. He is a member of the National Association of Safety Professionals (NASP) and a long-time contributor to No Jitter, where he has written on topics ranging from IT cost management to emerging technology trends. He previously served as Senior Vice President on the Board of Directors of the Society of Communications Technology Consultants (SCTC) and remains an active SCTC member. His vendor-independent positioning is not incidental. It is the foundation of everything 911ComplyPoint® does. Robert has no equipment to sell, no software license to push, and no manufacturer relationship that colors his recommendations. His only measure of success is whether your organization is genuinely prepared to manage a 911 emergency.