Business Phone Systems: VoIP, UCaaS, E911 and Number Porting

Choosing a business phone system used to mean buying a box for the closet and leasing lines from the phone company. Today most small businesses choose between an on-premises system and a cloud service that runs over the internet, often bundled with chat, video meetings and mobile apps.

The choice affects cost and features, but it also affects something easy to overlook: whether an employee who dials 911 reaches help quickly, with the right address. Federal rules now cover that, and they apply to cloud systems as well as traditional ones.

This guide explains the basics, the 911 rules and how to keep your phone numbers when you switch. It is general information, not legal advice. Ask your provider and, if needed, an attorney how the rules apply to your setup.

VoIP, Hosted Systems and UCaaS in Plain Terms

Voice over Internet Protocol (VoIP) carries calls over data networks. The Federal Communications Commission (FCC) defines interconnected VoIP as a service that enables real-time, two-way voice communications, requires a broadband connection and internet-protocol-compatible equipment, and lets users make and receive calls to and from the regular telephone network.

Your options usually fall into three groups:

• On-premises systems: a phone system installed at your office, often running VoIP internally.
• Hosted or cloud phone service: the provider runs the system and you pay per user.
• UCaaS, short for unified communications as a service: an industry term for cloud phone service bundled with messaging, video meetings and presence in one subscription.

For 911 purposes, the FCC's definition of a multi-line telephone system, or MLTS, is broad. It includes "network and premises based systems, such as Centrex and VoIP, as well as PBX, Hybrid, and Key Telephone Systems," whether owned or leased by businesses, nonprofits or government agencies.

What to Compare

Beyond price per user, compare:

• Call handling: auto attendants, call queues, ring groups, voicemail to email and business-hours routing.
• Apps: desktop and mobile apps that let staff use the business number from anywhere.
• Integrations with your customer relationship management system or help desk.
• Call recording, if you need it. Consent laws vary by state, so check with an attorney.
• Every line you have today, including fax lines, alarm panels and elevator phones, which may need special handling.
• Contract terms: length, price increases, taxes and fees, and what it costs to leave.

Reliability depends on your internet connection and power. FCC rules require interconnected VoIP providers to tell customers when 911 service may be limited, including after a broadband connection failure, a loss of electrical power or moving equipment to a new location. Plan for battery backup on network equipment, a backup internet connection or failover to mobile phones, and call-forwarding rules for outages. For contract and uptime terms, see our guide Vendor Management and SLAs: A Practical Guide for Small Businesses.

Kari's Law: Direct 911 Dialing and Notification

Kari's Law, signed on February 16, 2018, requires multi-line telephone systems to let users dial 911 directly, "without dialing any additional digit, code, prefix, or post-fix, including any trunk-access code such as the digit 9." It applies to systems manufactured, imported, first sold or leased, or installed after February 16, 2020.

The FCC's rules also require anyone in the business of installing, managing or operating such a system to configure notification to a central location or a designated person, when the system can do so without a hardware or software upgrade. The notification must be sent as the 911 call is placed when technically feasible, must not delay the call, and must go "to a location where someone is likely to see or hear it," such as a front desk or office manager.

The FCC's 2019 order clarified that Kari's Law applies to both legacy and internet-based systems, including cloud-based services. The rules place duties on manufacturers and sellers and on installers, managers and operators. In a cloud system, responsibilities may be split between you and your provider, so get the division in writing.

RAY BAUM'S Act and Dispatchable Location

RAY BAUM'S Act directed the FCC to consider rules to ensure that dispatchable location is sent with 911 calls regardless of the technology used. The FCC adopted those rules in 2019, effective January 6, 2020. Its definition of dispatchable location is the validated street address of the caller plus details such as a suite or similar information needed to find them.

For multi-line telephone systems, the deadlines have passed:

• On-premises fixed phones were required to provide automated dispatchable location by January 6, 2021.
• On-premises devices that move, such as softphones and wireless handsets, had until January 6, 2022, to provide automated dispatchable location when technically feasible, and otherwise a location updated by the user or alternative location information.
• Off-premises devices, such as a laptop softphone at home, had until January 6, 2022, to provide automatic dispatchable location if technically feasible, and otherwise a user-updated location or the best available enhanced location.

Interconnected VoIP providers must also obtain each customer's registered location before service begins and give users ways to update it.

In practice, this means maintaining accurate addresses down to the floor or suite. For example, Microsoft's Teams documentation describes emergency addresses with "places" such as a floor or building, dynamic emergency calling that detects a user's location from the network, and security desk notifications during emergency calls. Other platforms offer similar settings; ask your provider how theirs work, how remote workers confirm their location, and what testing option it supports instead of calling 911.

Keeping Your Numbers: How Porting Works

Number porting moves your existing numbers to a new provider. FCC rules require carriers to complete a simple port, including one involving interconnected VoIP, within one business day unless a longer period is requested. Non-simple ports must be completed within four business days. The rules allow longer periods when the new provider or the customer requests one, so ask your new provider for a realistic date.

Details matter. Microsoft's porting guidance for Teams, as one example, says the billing telephone number, account number, PIN, authorized user and service address must match the current provider's records exactly, and that a port request will be rejected if the billing number is incorrect or the account has a freeze on it. You will sign a letter of authorization. A full port moves every number on the account and closes it; a partial port leaves some numbers behind.

A practical porting checklist:

1. Inventory every number, including fax, toll-free and alarm lines.
2. Get a recent bill and confirm the account details and authorized user.
3. Set up and test the new system before the port date.
4. Keep the old account active and paid until the port completes and inbound calls are tested.
5. Update 911 addresses and notification settings on the new system before go-live.

Key takeaways

• Cloud phone systems and UCaaS can count as multi-line telephone systems under FCC 911 rules.
• Kari's Law requires direct 911 dialing without a prefix and on-site notification where the system supports it.
• Dispatchable location rules mean keeping accurate addresses, down to floor or suite, for office and remote users.
• Simple ports must be completed within one business day, but mismatched account details can get a port rejected.
• Plan for internet and power outages, and get 911 responsibilities in writing from your provider.

Sources

• Public Law 115-127, Kari's Law Act of 2017 (February 16, 2018)
• FCC, Implementing Kari's Law and RAY BAUM'S Act, Final Rule, 84 FR 66716 (December 5, 2019)
• eCFR, 47 CFR 9.16, General obligations: direct 911 dialing, notification, and dispatchable location
• eCFR, 47 CFR 9.11, E911 Service
• eCFR, 47 CFR 9.3, Definitions
• eCFR, 47 CFR 52.35, Porting Intervals
• Microsoft, Plan and manage emergency calling (Teams)
• Microsoft, Transfer phone numbers to Microsoft Teams