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Chapter 7 of 9

911 for schools, in plain English

You'll understand the two federal 911 rules for multi-line phone systems, which parts your provider usually handles and which your school handles, and how to test without tying up 911.

9 min read For IT, Leadership, Office staff Updated October 20, 2026

When someone in your school dials 911, three things matter. The call has to connect right away. Someone on site needs to know help is coming. And responders need to know exactly where to go. Two federal laws cover these points for phone systems like the ones schools use. This chapter explains them in plain words, shows what a provider usually sets up and what your school sets up, and walks through how to test safely.

Note: This is general information, not legal advice. Your provider, your local 911 agency and your attorney can tell you what applies to your sites.

A few terms first:

  • MLTS (multi-line telephone system): any phone system where many phones share a system and its outside lines. Almost every school phone system is one, including hosted (cloud) systems.
  • PSAP (public safety answering point): the local 911 call center that answers the call.
  • Dispatchable location: the address plus details such as building, floor and room that responders need to find the caller.
  • FCC (Federal Communications Commission): the federal agency that writes the rules for phone service. Its rules are published in the Code of Federal Regulations (CFR).

Kari’s Law: dial 911 directly, and tell someone on site

Kari’s Law is a federal law that applies to phone systems manufactured, sold, leased or installed after February 16, 2020 (FCC; Public Law 115-127, as of Oct 2026). A new system you buy today is covered. It has two parts.

1. Direct dialing. Anyone must be able to dial 911 from any phone on the system without a prefix. That holds even if people dial “9” or another code for other outside calls (47 CFR 9.16, as of Oct 2026). A substitute teacher, a visitor or a student should be able to pick up any phone and dial 911.

2. Notification. When someone dials 911, the system must alert a central location at the site, or another person or office. This applies where the system can do it without a hardware or software upgrade. The alert must start when the call starts, must not delay the 911 call, and must go where someone is likely to see or hear it (47 CFR 9.16, as of Oct 2026).

At a minimum, the alert must include (47 CFR 9.3, as of Oct 2026):

  • that a 911 call was made;
  • a callback number;
  • the location information the system sent to 911.

The callback number and location can be left out only if it’s technically infeasible to include them (same source).

What this looks like at a school: the front office phone shows an alert, or the principal and office manager get an email or text. Pick people who are on site during the school day. Then think about evenings, weekends and summer. Who should get the alert when the office is closed?

RAY BAUM’S Act: send a location responders can use

RAY BAUM’S Act is a 2018 federal law. Its Section 506 led the FCC to require that 911 calls carry a dispatchable location (FCC, as of Oct 2026).

The FCC defines that as a validated street address plus extra details, such as a suite or similar information, needed to find the caller (47 CFR 9.3, as of Oct 2026). On a campus, that usually means the building, the floor and the room. A street address alone doesn’t tell responders which of six buildings to run to.

The FCC set these dates (47 CFR 9.16, as of Oct 2026):

Kind of phone Requirement Since
Desk phones that stay in one place on site Send the dispatchable location automatically January 6, 2021
Phones that move around on site (for example, a wireless handset or a laptop app) Send it automatically if technically feasible; otherwise the user updates it by hand, or other location information is used January 6, 2022
Phones used off site (for example, a softphone at home) Send it automatically if technically feasible; otherwise the user updates it by hand, or the best available location is used January 6, 2022

Tip: Ask your local 911 agency what level of detail helps them most. Some schools set a location for every room. Others group nearby rooms into zones. Either way, make the names match the signs on your buildings (“Building C, Room 214”), not internal codes.

Who sets up what

With a hosted phone system, the work is shared. The FCC said a hosted provider is responsible for these rules “to the extent that its hosting service includes those functions.” It also said that if a system doesn’t comply, the organization that manages it is presumed to be at least partly responsible (FCC 19-76, as of Oct 2026).

In other words, your school keeps real duties even when a provider runs the system. Go through this table with your provider and write down who owns each item.

Task What a provider usually does What your school usually does
Direct 911 dialing Builds the dialing rules so 911 works from every phone with no prefix Confirms it on every kind of phone you have (desk, cordless, conference, app)
Notification Offers alert options (on-screen, email, text, call) Chooses who gets alerts, covers after-hours, and keeps the list current
Dispatchable location Sends the location with each 911 call and checks addresses against 911 records Gives an accurate building, floor and room for every phone, and reports moves
Moves, adds and changes Updates location records when asked Tells the provider before a phone moves or a room is renumbered
Remote staff and apps Provides a way for users to set or update their location Trains staff to keep their location current
911 limits notice and labels Tells you when 911 may not work, gets your acknowledgment, and supplies warning labels Reads the notice, signs the acknowledgment, and puts labels on or near phones
Testing Helps plan tests and shows what location is on file Schedules tests with local 911 dispatch and keeps records

Important: No phone system makes a school “compliant” on its own. Compliance depends on how the system is set up and kept up, including the location for every phone and who receives alerts. Those settings need checking every time a phone moves.

Softphones, mobile apps and remote staff

Softphones (phone apps on a computer) and mobile apps work anywhere, which makes location harder.

For phone service that can move, the FCC requires the provider to send the location automatically if that’s technically feasible. If it isn’t, the rule allows a few fallbacks. One is a registered location. The provider collects your location before service starts and lets you update it. It also has to notice when a 911 call comes from a different place, and then either prompt you for a new location or update it automatically (47 CFR 9.11, as of Oct 2026).

For your staff, that means:

  • Show anyone who uses a softphone or app how to check and update their location.
  • Remind them to update it when they work from home or another site.
  • Give them a simple rule for emergencies away from campus, for example using a cell phone’s built-in dialer.

Power and internet outages

Hosted phones need power and an internet connection. Many desk phones get power through the network cable from a network switch (this is called PoE, or power over Ethernet). If the building loses power or internet, those phones may stop working.

Your provider must tell you, clearly and in plain language, when 911 may not work or may be limited. The FCC’s list includes (47 CFR 9.11, as of Oct 2026):

  • a power outage;
  • an internet outage;
  • moving equipment to a new place;
  • using a number that isn’t native to that location;
  • delays in getting the location into the 911 database.

The provider must get your acknowledgment. It must also give you warning labels for phones or warn you in another clear way (same source).

Plan ahead:

  • Put the network switches, router and firewall that phones depend on on battery backup (a UPS, or uninterruptible power supply), and know how long it lasts.
  • Ask whether a backup internet connection makes sense for your main sites.
  • Add phone outages to your emergency plan, including when to use cell phones.

Train your staff

A short briefing at the start of the year, plus a one-page handout, goes a long way.

  • Dial 911 directly. No “9” is needed.
  • Stay on the line. Say where you are (building and room), even though the system sends a location.
  • If you dial 911 by mistake, don’t hang up. Stay on the line and tell the call-taker it was an accident.
  • Know what happens next. Explain who gets the alert and what they do: meet responders at the entrance, unlock gates, and call the district office.
  • Include everyone who uses the phones, not just teachers: substitutes, new staff, custodians, after-school and evening programs.
  • Remote staff: keep your app location up to date.

Labels

  • 911 warning labels: put your provider’s labels on or near phones, as the notice describes.
  • Location labels: a small label on each phone helps a caller, or a substitute, tell the call-taker where they are. For example: “This phone: Building C, Room 214. Dial 911 directly.”
  • Check them: compare labels with the locations on file in your phone system. A label that says Room 214 doesn’t help if the system sends Room 114.

How to test 911 safely

Important: Never dial 911 just to test. A test call can tie up call-takers who are handling real emergencies. Plan every test ahead with your provider and your local 911 agency.

California’s Office of Emergency Services (Cal OES) publishes a short guide on testing a phone with 911. It says to start with your local police or sheriff’s non-emergency number (Cal OES, as of Oct 2026). Outside California, the steps are similar, but check with your state or local 911 agency.

  1. Start with your provider. Ask how they recommend testing, and ask them to show you the location on file for the phones you’ll test.
  2. Call the non-emergency number for your local police or sheriff. Ask to schedule a test call with the 911 center. Not every police or sheriff’s office is a 911 center, but they can connect you. They may ask questions to confirm who you are and that there’s no emergency. They may also ask you to call back at a quieter time (Cal OES, as of Oct 2026).
  3. At the agreed time, dial 911. Say right away: “This is a test call, not an emergency.”
  4. Confirm what they see: the address, callback number and location details.
  5. Check the alert. Did the right people get it, with the right information?
  6. Fix mismatches right away. If the location is wrong, contact your provider to correct it (Cal OES, as of Oct 2026). Then schedule a retest.
  7. Write it down: the date, time, phone tested, who you spoke with and the results.

Test after cutover, after big moves or changes, and from time to time after that. Ask the 911 center how many test calls they’re comfortable with. A practical approach is to test a sample from each building and each kind of phone, then check the rest of the location records in the system.

A quick 911 checklist

  • 911 works with no prefix from every kind of phone you have.
  • Alerts go to people who are on site, and after-hours alerts are covered.
  • Every phone has an accurate building, floor and room on file.
  • Someone is responsible for updating locations when phones move.
  • Softphone and app users know how to update their location.
  • You’ve read the provider’s 911 limits notice and returned the acknowledgment.
  • Warning and location labels are on or near phones.
  • Network equipment for phones is on battery backup, and there’s an outage plan.
  • Staff have been briefed, including substitutes and after-hours staff.
  • Test calls are scheduled with your provider and local 911 dispatch, and results are recorded.

For the full list of 911 items to compare between providers, see What schools and nonprofits actually need and How to compare quotes fairly.

Sources

  1. Multi-line Telephone Systems · FCC · checked October 20, 2026
  2. Kari's Law Act of 2017 (Public Law 115-127) · U.S. Government Publishing Office · checked October 20, 2026
  3. 47 CFR § 9.16 General obligations—direct 911 dialing, notification, and dispatchable location · U.S. Government Publishing Office (Code of Federal Regulations, 2025 edition) · checked October 20, 2026
  4. 47 CFR § 9.3 Definitions · U.S. Government Publishing Office (Code of Federal Regulations, 2025 edition) · checked October 20, 2026
  5. 47 CFR § 9.11 E911 Service · U.S. Government Publishing Office (Code of Federal Regulations, 2025 edition) · checked October 20, 2026
  6. Implementing Kari's Law and Section 506 of RAY BAUM'S Act, Report and Order (FCC 19-76) · FCC · checked October 20, 2026
  7. How To Test My Telephone With 9-1-1 · California Governor's Office of Emergency Services (Cal OES) · checked October 20, 2026