Although voice-over-Internet-protocol (“VoIP”) is not classified by the FCC as a regulated telecommunications service (like telephone service provided over the “public switched telephone network” or PSTN), VoIP services are nonetheless subject to certain regulatory requirements, and PCOs that provide VoIP service at MDU properties need to be aware of those requirements. 

  1. E-911

In June 2005, the FCC released emergency calling (E-911) rules applicable to “all providers of interconnected VoIP service, whether or not such services are otherwise regulated under State or Federal law. The rules include (a) mandatory provision of E-911 calling capability; (b) subscriber self-reporting of his/her location; (c) affirmative notice to subscribers; (d) warning label requirements on or near IP compatible customer premises equipment (CPE); and (e) delivery of a compliance report to the FCC.

The rules can be found at 47 C.F.R. §§ 9.1 – 9.5 (2005).

Further information can be found at the FCC website:

  1. CPNI

In 2007 the FCC adopted additional rules concerning carrier treatment of so-called “Customer Proprietary Network Information” (“CPNI”).  While CPNI rules have been around since the passage of the 1996 Telecom Act, the widespread growth of VoIP services has resulted in the expansion of the CPNI rules to encompass interconnected VOIP service providers.

CPNI is personally identifiable information that a telecommunications carrier collects when providing telephone service to a subscriber.  It includes information related to the quantity, technical configuration, type, destination, location, and amount of use of a telecommunications service by a customer, as well as local or long distance telephone billing information.  CPNI does not, however, include subscriber lists.  Practically speaking, CPNI typically consists of phone numbers called by a customer, the frequency, duration, and timing of such calls, as well as any incidental services (e.g., call waiting) purchased by that telephone customer.

The FCC’s current CPNI rules are quite complex.  Section 222 of the Communications Act requires telecommunications carriers to take specific steps to ensure that CPNI is adequately protected from unauthorized disclosure. 

The FCC’s rules governing CPNI can be found at 47 C.F.R. § 64.2001 – 64.2009:



VoIP, or Voice Over the Internet, is a technology that allows telephone traffic to travel over the Internet or other IP networks.  VoIP can provide unique feature sets, customized calling plans.  These plans can allow for unlimited outbound North American local and long distance calling as well as unlimited inbound 800 service all at a flat rate, with no usage charges and no added taxes.  If High Speed DATA/Internet is available in your complex, and it is managed correctly, you can now provide this service for your residents with no capital requirements.  Why not capture a portion of the revenue for these services rather than have it given to the local phone companies?

  • What is VoIP?

-          VoIP converts analog voice patterns and the telco signaling, required to make and receive phone calls on the Public Switched Telephone Network, into data patterns.  This data, which travels across the Internet or private networks, is then terminated on a VoIP device or re-converted back to the voice patterns and signaling required to complete the call to the PSTN.

  • How does it work?

-          A standard telephone can be used for this service.  Rather than being plugged into the wires connecting to the local telephone office, the phone is plugged into a device called an Analog Telephone Adapter (ATA).  The ATA acts as a bridge, connecting and converting the telephone activity into data packets then and connecting those packets to the Data network, or Internet.

-          Once the voice traffic is turned into data traffic, there are devices that route this data traffic to network end-points which convert the data traffic back into voice traffic so the call can be completed and conversation can take place.

  • What makes it different?

-          Traditional phone networks assign phone numbers to specific wires connecting homes/apartments/businesses to a central office.  When a call is placed to a phone number, it is routed to a specific pair of wires connected to a phone.  The phone rings, but only when connected to the specific wires assigned to the phone number.

-          VoIP uses a different set of rules.  The phone number is assigned to the ATA device itself, not to a specific physical location.  Since the ATA can be connected to any High Speed Data connection, when it’s number is dialed any phone connected to it will ring.  The concept of local numbers has been changed, your number can travel with you anywhere in the world.

-          Because VoIP is a portable service, once a number is assigned to an ATA, or customer, it remains the same, giving one a phone number for ever.  Because the ATA can be allowed to remain with the resident when they move, allowing them to keep their phone number, they remain your customer and your revenue stream grows even if your residents move.  They are still your customer.

  • Why should VoIP be offered to my residents?

-          Currently, revenue sharing is non-existent with traditional phone providers.  VoIP can produce a revenue stream the PCO/MDU owner can be a part of.  With High Speed Data being offered as part of your media package, VoIP can be deployed with no extra capital expenditure, no extra infrastructure costs.  Your High Speed Data customers are already paying for the bandwidth needed for VoIP, the ATA’s are provided by your VoIP provider.  Thus, you gain a new revenue stream utilizing existing systems you have in place.

-          VoIP can offer feature sets not available with traditional phone service.

  • Advanced call forwarding/ follow me features
  • Unified messaging – voice mail and faxes can be listened to read via email
  • Multiple numbers from different parts of the country can be pointed at the same phone.
  • Multiple phones with different numbers can ring when a single number is dialed.
  • Web based viewing and setting of features and call logs.

-          VoIP completes the “triple play” of video, data and voice in your media offerings for your tenants.

-          VoIP offers lower cost options to your residents for services.  Why not be a part of the revenue these services produce?

  • What are the concerns/drawbacks of VoIP?

-          E911-  Many VoIP providers are now able to provide “traditional” like E911 services.  They can route calls to the proper E911 center, providing name, address and phone number to the center.  If an end-user moves, they can have access to tools that allow their information to be updated and routed to new centers where they now live.

-          All VoIP devices require power and Internet connectivity to function.  VoIP contracts must make users aware of these conditions and users should always be aware that they do not have traditional phone service.  Power is really not an issue that it once was as most consumer phones require power to function.

In summary, VoIP offers consumers a higher level of phone service at a lower price.  By bringing this service to residents through existing or new media distribution systems, combining VoIP services with High Speed Data, an untapped revenue stream opens for MDU owners and PCO’s.