Background

Back in August of 2019, the Federal Communications Commission (FCC) conducted an open commission meeting which resulted in new regulations on how to do E911 and deal with location information services. The new regulations were implemented over the past few years in phases giving phone system manufacturers and organizations time to not only develop innovative technologies but also implement them. In January the last regulations went into effect and the most interesting one is affecting external and work from home users, as modern technology had to be developed to address this scenario.

  • Dispatchable location for off-premises devices – 47 CFR §9.16(b)(3)(iii)

Microsoft released features in Teams in December 2021 to address the new external and work-from-home regulations, and this article will detail how to enable the features and explain the various scenarios when calling 911.

Configuration of Dynamic E911 for External and Work from Home (WFH) Users

Step 1 – Update all US “Emergency Calling Policies” to enable “External Location Lookup Mode”

  • Go to Microsoft Teams Admin Center – https://admin.teams.microsoft.com/
  • Expand “Voice” -> Click on “Emergency Policies” -> Click on appropriate US policy
  • Turn On “External Location Lookup Mode” -> Click “Apply”
  • Repeat this for all other US “Emergency Calling Policies”

Step 2 – Disassociate Emergency Response Links (ERLs)

  • If using Intrado, disassociate Emergency Response Links (ERLs) form subscribers and DID ranges in the Intrado self-service portal – ref: Intrado ERS Users Guide, Editing and Deleting ERLs.
  • If using DRaaS carrier such as Pure IP, open ticket with carrier to request the dissociation of ERLs from whichever backend Emergency Routing Service Provider (ERSP) they are using.
  • If using Microsoft Calling Plans, do nothing as you cannot disassociate the civic address from a Calling Plan. Calling Plans behave differently than Direct Routing in this regard.
  • Test dissociation by dialing 933 from external/home office location without any VPN enabled.

The correct behavior is if the announcement is reporting the number is NOT provisioned for 911 and that if 911 had been dialed this call would have been delivered to the national call center for routing to the appropriate Public Safety Answering Point.   

The incorrect behavior is if the announcement is reporting the number is provisioned for 911 and associated with a corporate office location address. The disassociation did NOT take effect and will need to be addressed as any emergency calls from external / work from home location will be routed to an inappropriate Public Safety Answering Point (PSAP) based on the corporate address location.

Dynamic E911 Scenarios

Scenario 1 – Correct location match provided by network for corporate office user

  • The location is provided to the Teams client by the corporate network and cannot be changed by the user.
  • When dialing 933 to test, the announcement should report the number is provisioned for 911 and associated with the appropriate corporate office location address.
    • The location will be provided in the Teams notification.
  • When dialing 911 the call will route to the appropriate public safety answering point (PSAP) bypassing the National Call Center / Emergency Call Relay Center (ECRC).
    • The location will be provided in the Teams notification.
    • The address will be provided to Public Safety Answering Point (PSAP).

Scenario 2 – Correct location match provided by operating system for external / home user

  • The location is provided to the Teams client by Windows and should be confirmed by the user.
  • If the user confirms the address and dialing 933 to test, the announcement should report the number is provisioned for 911 and associated with the provided location address.
    • The location will be provided in the Teams notification.
  • If the user does not confirm the address and dialing 933 to test, the announcement should report the number is not provisioned for 911 and that if 911 had been dialed this call would have been delivered to the national call center.
  • If the user confirms the address and dialing 911 the call will route to the appropriate Public Safety Answering Point (PSAP) bypassing the National Call Center.
    • The location will be provided in the Teams notification.
    • The address will be provided to the Public Safety Answering Point (PSAP).
  • If the user does not confirm the address and dialing 911 the call will route to the National Call Center for routing to the appropriate Public Safety Answering Point (PSAP).
    • The location will be provided in the Teams notification.
    • The address will not be provided to the National Call Center.

Scenario 3 – Incorrect or partial location match provided by operating system for external / home user

  • Location is provided to the Teams client by Windows and should be edited by the user.
  • If the user edits the address and dialing 933 to test, the announcement should report the number is not provisioned for 911 and that if 911 had been dialed this call would have been delivered to the national call center.
    • The correct location will be provided in the Teams notification.
  • If the user does not edit the address and dialing 933 to test, the announcement should report the number is not provisioned for 911 and that if 911 had been dialed this call would have been delivered to the national call center.
    • The incorrect or partial location will be provided in the Teams notification.
  • If the user edits the address and dialing 911 the call will route to the National Call Center / Emergency Call Relay Center (ECRC) for routing to the appropriate Public Safety Answering Point (PSAP).
    • The correct location will be provided in the Teams notification.
    • The address will not be provided to the National Call Center.
  • If the user does not edit the address and dialing 911 the call will route to the National Call Center / Emergency Call Relay Center (ECRC) for routing to the appropriate Public Safety Answering Point (PSAP).
    • The incorrect or partial location will be provided in the Teams notification.
    • The address will not be provided to the National Call Center.

Scenario 4 – No location match provided by operating system for external / home user

  • Location is provided to the Teams client by Windows and should be edited by the user.
  • If the user edits the address and dialing 933 to test, the announcement should report the number is not provisioned for 911 and that if 911 had been dialed this call would have been delivered to the national call center.
    • The correct location will be provided in the Teams notification.
  • If the user does not edit the address and dialing 933 to test, the announcement should report the number is not provisioned for 911 and that if 911 had been dialed this call would have been delivered to the national call center.
    • No location will be provided in the Teams notification.
  • If the user edits the address and dialing 911 the call will route to the National Call Center / Emergency Call Relay Center (ECRC) for routing to the appropriate Public Safety Answering Point (PSAP).
    • The correct location will be provided in the Teams notification.
    • The address will not be provided to the National Call Center.
  • If the user does not edit the address and dialing 911 the call will route to the National Call Center / Emergency Call Relay Center (ECRC) for routing to the appropriate Public Safety Answering Point (PSAP).
    • The no location will be provided in the Teams notification.
    • The address will not be provided to the National Call Center.
Emergency address classification and routing

The following table shows the types of emergency addresses and associated routing methods for each type: whether the call is automatically routed to the serving PSAP or screened for accuracy before transferring to the serving PSAP. This routing behavior is supported in the United States for all Calling Plan users, Operator Connect partners, and Direct Routing certified emergency calling service providers.

Type of emergency addressEmergency routing method
Scenario 1 – Location provided by the corporate network Dynamically acquired emergency address defined by administrator.Direct to PSAP.
Scenario 2 – Correct location provided by the OS
Emergency address obtained from the operating system with confirmation for accuracy by the user.
Direct to PSAP.
Scenario 2 – Correct location provided by the OS
Emergency address obtained from the operating system without confirmation for accuracy by the user.
Screened and Transferred to PSAP.
Scenario 3 – Incorrect/partial location provided by the OS Emergency address obtained from the operating system and edited and confirmed by the user.Screened and Transferred to PSAP.
Scenario 4 – No location is provided by the OS
Emergency address entered and confirmed by the user.
Screened and Transferred to PSAP.
Reference:

Multi-line Telephone Systems – Kari’s Law and RAY BAUM’S Act 911 Direct Dialing, Notification, and Dispatchable Location Requirements – FCC

https://www.fcc.gov/mlts-911-requirements

Emergency addresses for remote locations – Microsoft Teams | Microsoft Docs

https://docs.microsoft.com/en-us/microsoftteams/emergency-calling-dispatchable-location

Windows Devices Geolocation Namespace – Windows UWP applications | Microsoft Docs

https://docs.microsoft.com/en-us/uwp/api/Windows.Devices.Geolocation