RAY BAUM'S Act: Dispatchable Location for 911

Section 506 of RAY BAUM'S Act requires that a "dispatchable location" be sent with every 911 call, including calls from business phone systems: the validated street address plus the suite, floor or room needed to find the caller. For business phones, the FCC phased this in on January 6, 2021 for fixed desk phones on site and January 6, 2022 for non-fixed devices and phones used off-premises, such as softphones used by remote staff.

In practice, it means your phone system must know where each caller is, in enough detail to send help to the right door.

What the law is

RAY BAUM'S Act is a 2018 federal law; Section 506 directed the FCC to make sure dispatchable location is conveyed with 911 calls regardless of the technology used. The FCC adopted the implementing rules in August 2019 alongside the rules for Kari's Law. Kari's Law covers direct dialing and notification; RAY BAUM'S Act covers location. Read Kari's Law for business phones for the other half.

Dispatchable location, defined

Under 47 CFR § 9.3, dispatchable location means "the validated street address of the calling party, plus additional information such as suite, apartment, or similar information necessary to adequately identify the location of the calling party."

Example	Dispatchable?
"123 Main St, Columbus, OH 43215" for a 20-story tower	Not enough for a large building
"123 Main St, Suite 1450, 14th floor, Columbus, OH 43215"	Yes
"Warehouse, 55 Dock Rd, Bay 3"	Yes, if Bay 3 is how responders find it
GPS coordinates only	Not dispatchable location, though may qualify as alternative information for some devices

The rules for business phone systems (MLTS)

The FCC's MLTS 911 page sets out deadlines by device type.

Device type	Deadline	What must be provided
On-premises, fixed (desk phones that stay put)	January 6, 2021	Automated dispatchable location
On-premises, non-fixed (devices that move within the site)	January 6, 2022	Automated dispatchable location if technically feasible; otherwise dispatchable location from manual user update, or alternative location information sufficient to identify civic address and approximate in-building location, including floor in large buildings
Off-premises (e.g. softphone at home or traveling)	January 6, 2022	Automated dispatchable location if technically feasible; otherwise dispatchable location from manual user update, or enhanced location information (best available location at reasonable cost)

These obligations apply to MLTS manufactured, imported, offered for first sale or lease, sold, leased or installed after February 16, 2020.

The rules for VoIP providers

Interconnected VoIP providers have parallel obligations in 47 CFR § 9.11: automated dispatchable location for fixed service since January 6, 2021, and for non-fixed service since January 6, 2022 a hierarchy of options that includes automated dispatchable location if feasible, a registered location the customer can update, alternative location information, or routing to a national emergency call center. See E911 for VoIP business phones.

Who does what

Party	Typical responsibility
Phone system or VoIP provider	Ability to store and send location; prompts to update; delivery to 911
Installer	Configure the system to convey location
Business (manager/operator)	Enter accurate addresses; keep them current; tell staff to update
Employee	Update location when working somewhere new, where the system relies on manual updates

The rules place obligations on managers and operators, which is often the business itself. A provider can build the capability, but only you know that accounting moved to the third floor.

Remote and hybrid work

This is where most businesses fall short. A remote employee using a softphone on a laptop is an off-premises device. If the system cannot detect location automatically, the fallback is a manual update by the user. That only works if:

• The employee knows they must update it
• Updating is easy
• They actually do it when they move

Write it into your remote work policy: "Before you make or take calls from a new location, update your emergency address."

Building a location plan

1. Inventory devices. Desk phones, conference phones, softphones, mobile apps.
2. Classify each. Fixed, on-premises non-fixed, or off-premises.
3. Map your space. Building address, suite, floor, wing or room naming responders would understand.
4. Assign locations. Register a dispatchable address for each fixed device or user.
5. Set update procedures for non-fixed and remote devices.
6. Review whenever you move, renovate, add floors or hire remote staff.

Writing location details responders can use

The extra line after the street address is the part that saves time. Think about how a firefighter who has never been inside your building would find the caller.

Weak location detail	Better location detail
"Back office"	"Suite 210, second floor, rear of building, entrance on Oak St"
"Annex"	"Building B, single-story, east of main parking lot"
"Shop"	"Unit 4, roll-up door marked 4, north side"
"Upstairs"	"Floor 3, Room 312"

Use the same names that appear on signs, doors and building directories. If your building has a loading dock or side entrance responders should use after hours, add that to your internal emergency note and make sure the person who receives 911 notifications knows it. Suite numbers should match what the building management and the post office use; a validated address is one that matches official address records, so invented unit names may not validate.

Large buildings and campuses

The FCC defines dispatchable location as a validated street address plus additional information, such as suite, apartment or similar details, needed to adequately identify the caller's location. In a single-floor shop, the street address and suite may be enough. In a multi-story office, include the floor and, where useful, a wing or room. On a campus with several buildings at one address, include the building name or number. Write it the way a responder walking in the door would need it, and test that your phone system shows the same text you entered.

Common mistakes

• Using the mailing address or headquarters address for everyone
• Leaving off the suite or floor
• Setting a remote worker's address once and never revisiting it
• Naming locations with internal jargon ("the Annex") that responders will not understand
• Testing by calling 911 (do not; ask your provider how to verify)

Compliance checklist

• Every fixed device has a validated dispatchable address
• Suite, floor or room included where needed
• Non-fixed and remote devices have an update method
• Staff told when and how to update
• Kari's Law direct dialing and notification in place
• Review triggered by moves and new hires

Dispatchable location on Callata

Callata registers a dispatchable address for each account, including suite or floor, and sends that address with your business number to the dispatcher whenever someone on the account dials 911. If you move or use the service somewhere else, you update it in Admin under Numbers & 911, and Callata's 911 disclosure tells you to do so before relying on 911. Because Callata stores one registered address per account, staff who work away from that address should be told to update it or use a mobile phone for emergencies. When 911 is dialed, Callata also emails the account owner and can text a number you choose. Every number includes E911 on the $99 monthly plan. Get started.