VoIP 911 Policy

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Policy Title: Emergency Calling (911) Policy for Voice over IP (VoIP) Services, Including Microsoft Teams

Effective Date: January 1, 2026

Policy Owner: iTech Department, The University of Southern Mississippi

Approval Authority: Directory of Technology Operations and Infrastructure

Revision History: Version 1.2 - Revised Draft [August 6, 2025]

1. Purpose

This policy establishes guidelines for the use of Voice over Internet Protocol (VoIP) services, including Microsoft Teams Calling, to ensure reliable access to emergency services (911) while complying with federal regulations such as FCC E911 requirements, Kari's Law and RAY BAUM's Act. Recognizing the mobility of modern university environments, this policy prioritizes accurate location determination, user accountability, and innovative enhancements to mitigate risks associated with WiFi-based or mobile clients. It aims to disrupt outdated practices by integrating emerging technologies for improved safety, cost efficiency, and process optimization, all while upholding exceptional customer service for faculty, staff, students, and visitors.

2. Scope

This policy applies to all users of USM-provided VoIP services, including but not limited to Microsoft Teams on desktops, mobile apps, and other softphones, as well as wired VoIP phones (e.g., Cisco or Teams desk phones). It covers on-campus and off-campus usage, wired and wireless connections, and integrations with third-party providers like Intrado for E911 routing. Exemptions include traditional landline phones and cellular services not managed by iTech.

3. Definitions

E911 (Enhanced 911): A service that automatically provides the caller's location to emergency responders.
Location: A dispatchable location including building address, floor, and specific area (e.g., room or zone).
Access Point (AP): WiFi hardware used to approximate user location based on connection.
Softphone: VoIP software (e.g., Teams app) on mobile or desktop devices, which may not provide precise location data.
Wired VoIP Phone: A VoIP device (e.g., desk phone) connected to a network port, fixed in one location, and managed by iTech to ensure accurate location data.
Public Safety Answering Point (PSAP): The facility that receives 911 calls and dispatches responders.
Artificial Intelligence (AI): Technology that enables machines to simulate human intelligence, such as for location prediction and automation.
Internet of Things (IoT): A network of interconnected physical devices that collect and exchange data over the internet.
Intrado: A third-party provider of E911 routing and location management services for VoIP systems.

4. Location Determination and Accuracy

USM leverages Intrado's E911 services integrated with Microsoft Teams and Cisco VoIP systems to provide dynamic location information. Location is determined as follows:

Wired VoIP Phones: Automatically via network switch ports, mapped to precise locations (address, floor, area). These devices are fixed and managed by iTech, ensuring accurate E911 data regardless of user login (e.g., in Teams or Cisco systems). Wired phones consistently convey the most detailed location information to 911 operators and are recommended method for emergency calls.
Wireless/WiFi Connections: Based on the connected AP, capturing address, floor, and area. While this offers reasonable accuracy, it may not pinpoint exact rooms due to signal overlap or user movement. Softphone applications (e.g., Teams on WiFi) rely on user-registered location data, which may be less precise, and not recommended for 911 calls.
Mobile/Softphone Clients: Relies on device location services (if enabled) or manual user entry. Off-campus calls default to manual input or device GPS, potentially routing to a national PSAP if undetected.
Recommendation for 911 Calls: For the purpose of this policy, a wired VoIP phone (e.g., desk phone) is a VoIP device wired to a network port and consistently remains in one location, managed by iTech to prevent unauthorized moves. It is recommended that all emergency 911 calls be placed from a wired VoIP phone or cellular phone. If current location information is properly updated, wired VoIP phones will generally convey the most detailed location information to the 911 operator, whereas cellular phones only provide approximate location information. Regardless of the device from which the call is placed, it is crucial for the caller to give the address of their emergency to the 911 operator whenever possible.
Innovative Enhancements: iTech will explore integrations with AI-driven location prediction to refine sub-room accuracy for WiFi and mobile clients, reducing response times and operational costs through proactive mapping updates.

Users must enable location services in the Teams app and verify their location upon significant moves (e.g., building changes). The Teams app displays an "Emergency service disclaimer" at the top of the calling tab, reworded as: "For 911 Calls, Please remember to verify and if necessary set your Location." Automatic prompts will appear on IP address changes, with updates syncing to Intrado's database within minutes.

5. Procedures for 911 Calls

Initiating a Call: Dial 911 directly--no prefixes required (per Kari's Law). The system will route the call to the appropriate PSAP with available location data.
On-Campus Calls: Routed to local PSAP with location details.
Off-Campus/Remote Calls: Users must manually enter their location in Teams if prompted. Calls may route to a regional or national PSAP; always provide verbal confirmation of your exact location to the operator.
Testing: Non-emergency tests can be requested via iTech support. Use 933 (test line) where available to verify routing without alerting responders.
Outages or Failures: In case of internet or power disruptions, VoIP may be unavailable. Users should default to cellular phones or nearby landlines.

6. User Responsibilities

To ensure safety and compliance, users are accountable for:

Acknowledging this policy during onboarding or via M365 notifications, confirming understanding of limitations.
Verifying and, if necessary, setting their location promptly via the Teams app or iTech ticket system for any moves, adds, or changes (MACs) when using softphones or off-campus devices.
Enabling device location services and keeping software updated.
Preferring wired VoIP phones or cellular phones for 911 calls in mobile scenarios where WiFi accuracy is uncertain, as softphones may introduce delays or routing errors.
Reporting issues immediately to iTech for resolution.

7. Limitations and Risks

VoIP 911 is not infallible, particularly for mobile users:

Location data for softphones or WiFi-based devices may be imprecise (e.g., AP-based estimates could span multiple rooms).
Calls may fail during network outages, unlike traditional landlines.
Off-campus or VPN usage might route incorrectly without manual location input.
No guarantee of service in all scenarios; users must verbally provide details to operators.

These limitations are inherent to cloud-based systems but are mitigated through standards adherence and continuous enhancements. USM humbly acknowledges these challenges and encourages feedback to drive forward-thinking improvements.

8. Compliance and Enforcement

Regulatory Alignment: This policy ensures full compliance with FCC mandates, requiring location consent pre-activation and easy updates.
Audits: iTech will conduct periodic audits of location mappings and incident reviews to refine processes.
Violations: Failure to update locations or acknowledge policy may result in service suspension.
Monitoring: iTech will track metrics, like routing accuracy and response times, using data to reduce costs and enhance customer service.