Thursday, October 31, 2019

“New FCC 911 Enterprise Phone System Requirements - The National Law Review” plus 1 more

“New FCC 911 Enterprise Phone System Requirements - The National Law Review” plus 1 more


New FCC 911 Enterprise Phone System Requirements - The National Law Review

Posted: 23 Oct 2019 03:30 PM PDT

On August 2, 2019, the Federal Communications Commission ("FCC" or "Commission") released a Report and Order on 911 calling capability requirements that affect virtually anyone in the enterprise calling platform ecosystem, whether sellers, lessors, installers, managers and operators of what the FCC refers to as multi-line telephone systems ("MLTS"). The new rules also affect providers of Voice over Internet Protocol ("VoIP") services. The rules implement the requirements of two federal statutes: Kari's Law Act of 2017, which requires MLTS to be capable of direct 911 dialing and on-site notifications, and Section 506 of the RAY BAUM'S Act of 2018, which requires the Commission to "consider adopting rules to ensure that the dispatchable location is conveyed with a 9-1-1 call" over various types of calling platforms and technologies.

Kari's Law

What Is a Multi-Line Telephone System ("MLTS")?

MLTS encompasses virtually all multi-line enterprise and small office calling platforms, including premises and network-based PBX systems, Centrex, VoIP, Hybrid and Key Telephone Systems. MLTS includes cloud-based IP technology and over-the-top applications, as well as systems owned or leased by governmental agencies and non-profit entities, as well as for profit businesses.

Direct Dialing Requirement

Beginning February 16, 2020

Manufacturers, Sellers, and Lessors may NOT manufacture, import, offer for first sale or first lease an MLTS, unless it is pre-configured so that when installed, a user may direct dial 911 without the requirement of an initial step, such as dialing 9 to obtain an outside line.

Installers, Managers and Operators may NOT install, manager or operate an MLTS, unless it is configured so that a user may direct dial 911.

Location Notification Capability

Beginning February 16, 2020

Installers, Operators and Managers must ensure that equipment installed, managed or operated, is configured so that when a 911 call is placed, notification is provided to a central location at the facility where the system is installed or to another person or organization outside the location, unless the provision of that capability would require an improvement to the system hardware or software.

Notification Capability Requirements

Initiation of Notification : The initiation of the notification must be contemporaneous with the call to 911, unless it is technically infeasible to provide contemporaneous notification due to the configuration of the MLTS equipment.

Likelihood of Receipt of Notice : The notification must be sent to a location on-site or off-site where someone is likely to hear or see the notification.

Content of Notification : The notification must include: (1) the fact that a 911 call was made; (2) a valid callback number; and (3) with limited exceptions, the same location and callback information that is conveyed to the public safety answering point ("PSAP") with the call to 911.

RAY BAUM'S Act

Pursuant to RAY BAUM'S Act, the FCC adopted requirements across platforms and technologies, including MLTS and VoIP, for provision to PSAPs of "Dispatchable Location" when a 911 call is placed, i.e., validated street address, plus suite, apartment or similar information, such as floor and quadrant. The point of these changes is to allow emergency responders to pinpoint the location from where a 911 call was placed, particularly in office building and campus environments, where a phone number might otherwise be associated with a particular address or central location, rather than the actual location from where the call originated.

Recognizing that the technical ability to provide Dispatchable Location information will vary depending on whether a technology is fixed (such as location-fixed desk or hotel phones or fixed VoIP service used at particular location) or non-fixed (such as on-premises or off-premises portable soft phones and nomadic or mobile VoIP services), as described below, the Commission adopted one-year and two-year deadlines from the rules' effective date to allow for implementation. In addition, the manner of compliance with the Dispatchable Location requirements also differs by technology. Taken together, this provides some complexity on how the Dispatchable Location requirements are implemented that varies across these parameters. That said, unlike the Kari's Act rules which are effective in February 2020, the Dispatchable Location rules will not be effective until approved by the Office of Management, hence these one-year and two-year compliance periods will not begin to run until such approval is received.

One (1) Year from the Effective Date of the Dispatchable Location rules:

Fixed MLTS (e.g. hotel phones or fixed desk phones that each connect to a single access point) – Manufacturers, sellers/lessors, installers, operators must ensure that MLTS are configured to automatically provide:

Validated street address, plus suite, apartment or similar information (e.g. floor, quadrant).

Fixed VoIP – Providers must ensure that service automatically provides:

Validated street address, plus suite, apartment or similar information (e.g., floor, quadrant).

Location may be determined using the most recent information obtained by a VoIP provider identifying the physical location of the customer (known as "Registered Location"), (to the extent a physical address conveys a street address that is validated).

Two (2) Years from Effective Date of Dispatchable Location Rules:

On-Premises, Non-Fixed MLTS (e.g., softphones or mobile handsets that connect to multiple Wi-Fi access points and can move from one location to another within a building) must automatically provide:

Validated street address, plus suite, apartment or similar information (floor, quadrant) when technically feasible. If NOT technically feasible, provider may:

Rely on MLTS end user to provide or confirm Dispatchable Location information manually, e.g., by responding to a system prompt; or

Provide alternative location information, such as coordinate-based information, sufficient to identify the caller's address and approximate in-building location, including floor level, in large buildings.

Off-Premises, Non-Fixed MLTS (e.g., remote VPN access) – MLTS must automatically provide:

Validated street address, plus suite, apartment or similar information (floor, quadrant) if technically feasible. If NOT technically feasible, provider may:

Rely on MLTS end user to provide or confirm Dispatchable Location information manually, e.g., by responding to a system prompt; or

Provide enhanced location information, which may be coordinate-based, consisting of the best available location that can be obtained from any available technology or combination of technologies at reasonable cost.

Non-Fixed VoIP (i.e., nomadic or mobile VoIP) – Service must automatically provide:

Validated street address, plus suite, apartment or similar information when technically feasible. If NOT technically feasible, provider may:

Rely on end user to provide or confirm Dispatchable Location information manually, e.g., by responding to a system prompt; or

Provide alternative location information, such as coordinate-based information, consisting of the best available location that can be obtained from any available technology or combination of technologies at a reasonable cost. Alternative location information should be sufficient to identify the caller's address and approximate in-building location, including floor level, in large buildings.

If neither of the above methods are attainable using good faith efforts, the VoIP provider can route a 911 call to a national emergency call center for the operator to ask the caller directly for their location.

Outbound-Only Interconnected VoIP – Service must automatically provide:

Validated street address, plus suite, apartment or similar information when technically feasible. If not technically feasible, provider may:

Rely on end user to provide or confirm Dispatchable Location information manually, e.g., by responding to a system prompt; or

Provide alternative location information, such as coordinate-based information, consisting of the best available location that can be obtained from any available technology or combination of technologies at a reasonable cost. Alternative location information should be sufficient to identify the caller's address and approximate in-building location, including floor level, in large buildings.

Immunity from Liability

As a final note, the Commission also extended the immunity shield granted to emergency providers, fixed telephony, commercial wireless, and VoIP providers in existing law to MLTS sellers/lessors, installers, operators and managers in connection with the delivery of 911 emergency information to PSAPs.

Copyright © 2019 Womble Bond Dickinson (US) LLP All Rights Reserved.

Review of top 10 VoIP phone systems for small-to-medium size business - VoIp.Review

Posted: 26 Apr 2019 12:00 AM PDT

The current telecommunications market is abundant with a variety of business phone systems carefully designed to improve day-to-day communications and handle the complex needs of various organizations. Among the different existing types of telephone systems appropriate for use by small-to-medium size businesses, VoIP-related phone solutions are currently the most common and are growing in popularity.

VoIP phone systems operate using broadband Internet connections and generally include quick and easy installation, cost effective pricing, high scalability and advanced features with options to cater to any entity size, ranging from a small business to a multi-service enterprise.

A comprehensive VoIP solution should include a range of voice functions needed by the organization, and support both external and internal communications as required. Finding the most suitable phone system may be overwhelming, so for those currently on the lookout, here are the top ten VoIP phone systems to investigate.

Business VoIP solutions from Nextiva provide small businesses with an enterprise-level telephony service that helps them to establish an in-house VoIP phone system to enhance the efficiency and effectiveness of the company's communications. Nextiva offers integrated and scalable PBX trunks, online faxing and hosted call center solutions. The advanced features include auto-attendants, voicemail-to-email transcription, conference call capabilities, unlimited calling as well as state-of-the-art customer support.

The cloud-based phone.systems™ is an advanced, flexible, easy-to-use and feature-rich virtual platform that allows organizations to establish seamless global connections and increase business efficiency. The solution is highly interoperable and is specifically designed to interconnect with any VoIP provider. This platform is easy to set up and deploy without any expertise, and presents a unique web interface where users configure their phone system by simply dragging and dropping graphically-represented functional elements. The use of this product does not require the need to purchase any additional software or special hardware.

Furthermore, phone.systems™ is mobile compatible, and includes noteworthy powerful features such as the forwarding of voicemails as email attachments, distributing high volumes of incoming calls, displaying in-depth call logs, and creating online conference rooms. The proprietary Interlink feature allows users to link up with other phone.systems™ accounts and directly dial each other's internal (extension) numbers.

A provider of enterprise cloud communications and collaboration solutions, RingCentral enables the contemporary mobile and distributed workforce to connect and communicate in a cost-effective and flexible manner. The company's cloud PBX has multiple options for small businesses and large enterprises, and combines voice, video conferencing, team messaging, analytics, online fax and meetings, and also integrated omnichannel contact center solutions. Moreover, project management tools, conferencing options and file sharing features built into the platform assist in maximizing staff productivity and promote consistent collaborations throughout the company.

Experts rate this US-based VoIP provider highly for its combination of reasonable cost, user-friendliness and first-rate features. With an online portal, 8X8 system does not require PBX-style hardware or VoIP-enlightened IT professionals for its maintenance.  8X8 includes a rich array of features with options such as automated attendants, directory assistance, ring groups, caller ID blocking and on-hold music. Voicemail-to-Email and conference calling are offered for mobile employees. Collaboration tools include instant messaging, a presence feature showing who is available and who is busy, and the hosting of online meetings.

Vonage is one of the first phone companies to offer VoIP for business, and is currently one of the top phone service providers with its cloud-based phone system encompassing dozens of features. This solution includes unlimited calling, SMS messaging, voicemail, team messaging, call recording, multilevel auto-attendant, video conferencing and more. Even though Vonage's phone service includes many similar call management features to its competitors, the company's partnership with Amazon Chime sets the solution apart by integrating communication and collaboration tools within its phone system.

3CX is an open-standards PBX and is compatible with a range of SIP trunk providers, allowing for a fully functional IP PBX setup with a complete set of unified communications features. In addition to its easy installation and administration, the 3CX phone systems automatically controls security, backup, update and its repair management feature.  The PBX's built-in security includes automatic generation and management of SSL certificates, voice traffic encryption via SRTP, global IP blacklisting and provisioning of phones via uaCSTA. 3CX includes apps for iOS and Android, an intuitive web client, integrated WebRTC video conferencing, Click-to-Call, CTI and CRM integrations.

This flexible, cloud-based VoIP solution is best suitable for solopreneurs and budget-conscious small businesses with low-volume calling requirements. The Phone.com service offers packages of calling minutes with features such as an auto-attendant, voicemail-to-email, mobile apps, user extensions and call conferencing. Premium features include custom toll-free numbers, call recording, caller analytics, CRM integration and a live receptionist. In addition to a budget-friendly service plan, Phone.com is one of the few providers to offer low-price calling to selected countries outside the US, including Canada, France, Germany, Israel, Italy, Puerto Rico and the United Kingdom.

The cloud-based business VoIP services from Versature provide unified communications and call analytics solutions for business operations management. Versature's key features include, but are not limited to, auto-attendant, click-to-dial, simultaneous ring, voicemail-to-email transcriptions, phone directories and call recording. The company's call analytics software, Versature Insights, is a suite of tools that enables organizations to manage complex data, pinpoint efficiencies and detect valuable business trends. Furthermore, this phone system may be integrated with various cloud-based services, technologies and tools to obtain insights from call data and include them into business workflows.

Jive Communications delivers enterprise-grade hosted VoIP and cloud-based unified communications solutions across the US. The Jive Voice platform is designed to improve employee engagement and productivity, and to enhance the customer experience, ranging from marketing interactions to support and brand promotion. The company's integrated suite offers a PBX call routing system, broadband internet, automatic call distribution, call recording, conference calling, internet fax, mobility, and a softphone. The Jive solution is suitable for a broad range of organizations, from small businesses to large-scale enterprises.

The cloud-based VoIP Grasshopper phone service provides users with a virtual business phone number on their mobile or personal phones, eliminating the need for new equipment. This system was essentially designed for small offices wishing to present a more professional telecommunications facade to its customers. Grasshopper delivers a wide range of features including vanity phone numbers, unlimited calling, call forwarding, Wi-Fi calling, custom greetings, call screening and inbound fax which can, together with voice mail, be automatically converted to email. On the whole, the many favorable customer reviews emphasize how easy the Grasshopper system is to set up and use.


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