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Phones and the AI receptionist

Kari's Law

Kari's Law Act / direct 911 dialing / MLTS 911 rules / 47 CFR 9.16

In short

Kari's Law is the federal rule that lets anyone dial 911 from an office phone without pressing 9 or any other code first. It applies to phone systems installed or first sold after February 16, 2020. When a system breaks the rule, the business managing it is presumed responsible.

Kari's Law is a federal statute, 47 U.S.C. 623, carried out by an FCC regulation, 47 CFR 9.16. Both cover multi-line telephone systems, the kind a business with more than one line runs. The FCC's definition names Centrex and VoIP as well as PBX, hybrid and key systems, so a cloud phone service counts.

The core duty fits in a sentence. A caller must be able to reach 911 from any phone with a dial pad, without dialing any additional digit, code, prefix, or post-fix. The regulation names the usual obstacle outright: a trunk-access code such as the digit 9.

A second duty covers who finds out. The system must alert a central location at the facility, or another person or organization, when someone dials 911. The alert cannot delay the call, and it must reach a place where someone is likely to see or hear it. The statute limits this duty to systems that can do it without new hardware or software.

The rules took effect on February 16, 2020. They reach any system manufactured, imported, first sold or leased, or installed after that date. When the dialing or alert rules are broken, the regulation presumes the business managing the system is responsible.

A companion rule adds dispatchable location: the validated street address of the caller, plus details such as a suite number. For fixed phones on the premises, the deadline to send it automatically was January 6, 2021.

In practice

A dental practice moves to a cloud phone system in 2024. Staff press 9 to call out, and the installer left 911 behind that prefix. A patient collapses in the waiting room, a hygienist dials 911 without the 9, and the call fails. That failure is what the rule forbids. The call has to connect, and the front desk should get an alert that 911 was dialed.

Not the same as

STIR/SHAKEN
That framework lets carriers vouch for the caller ID on calls between networks. Kari's Law governs whether a person inside your building can reach 911 at all.

Why it matters to you

The dial plan is set by whoever installed the system, usually in a screen you never see. One setting decides whether 911 needs a prefix. The presumption of responsibility falls on whoever is in the business of managing the system, so get it in writing whether that is your vendor or you.

What to ask or check

  1. 01Can every phone in this building reach 911 without pressing 9 or any other code first?
  2. 02When someone dials 911, who on site gets an alert, and how does it arrive?
  3. 03What street address and suite does the system send with a 911 call?

What people get wrong

That a cloud phone service sits outside these rules because there is no equipment on site. The FCC's definition of a multi-line telephone system names VoIP and Centrex alongside PBX and key telephone systems.

Red flags

  • A phone guide that tells staff to press 9 for an outside line, with no exception for 911.
  • Nobody can say who on site is alerted when someone dials 911.
  • A contract that never states who manages the system.

Who owns it

The regulation splits the duty. Makers, importers, sellers and lessors must ship systems ready for direct dialing. Installers, managers and operators must keep them configured that way, and the manager is presumed responsible when the dialing or notification rules are broken.

STIR/SHAKEN

STIR/SHAKEN is how phone carriers sign outbound calls so the receiving network can tell the caller ID was not faked. The signature is your provider attesting to the accuracy of the number it is sending. Congress required it on internet protocol networks and asked only for reasonable measures elsewhere.

Telemarketing Sales Rule

The Telemarketing Sales Rule is the FTC rule governing sales calls. Beyond the do not call list, it sets what a caller must say and when they may call: residential calls only between 8am and 9pm local time, and a prompt disclosure that the purpose of the call is to sell something.

AI voice calls

An AI voice call uses a synthesized or cloned voice to speak to the person who answers. In February 2024 the FCC confirmed those voices fall under the existing rules on artificial or prerecorded voice, so the same consent requirements apply. The message must also identify your business and offer an automated way to opt out.

Call tracking

Call tracking replaces the phone number shown to a visitor with a substitute number that routes to your real one. Only calls dialed through that substitute are measured. Google assigns a forwarding number when call reporting is on, and Microsoft requires an ad group to have reached 10 clicks and 10 dollars of spend in 30 days.

National Do Not Call Registry

The National Do Not Call Registry is the federal list of numbers telemarketers may not call. Sellers subscribe by area code, and FTC guidance says call lists must be scrubbed against it at least every 31 days. Business to business calls are largely outside the rule, with narrow exceptions.

Caller ID spoofing

Caller ID spoofing is sending a number other than the line you are calling from. The federal prohibition is not about the technique. It applies to transmitting misleading or inaccurate caller identification information with the intent to defraud, cause harm, or wrongfully obtain anything of value.

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