It turns out the FCC has already covered this in their rulemaking for 
9-8-8<https://www.federalregister.gov/documents/2020/09/16/2020-16908/implementation-of-the-national-suicide-hotline-improvement-act-of-2018>.

“We decline to adopt a proposal to require multi-line telephone systems (MLTS) 
to allow callers to reach the Lifeline by dialing 988 and no other digits.” (I 
believe that “allow” in the quote above should really be “require”.)

They go on to explain that they are given the authority to require this for 
9-1-1 by Kari’s Law, but that they lack a similar authority with regard to 
9-8-8.

So, while it is not required for MLTS to support both 9-988 and 988. I still 
feel that it is a good idea to do so if feasible.

David Zilk


From: Brandon Svec <bs...@teamonesolutions.com>
Sent: Friday, July 15, 2022 9:21 AM
To: Zilk, David <david.z...@cdk.com>
Cc: VoiceOps@voiceops.org
Subject: [EXTERNAL] Re: [VoiceOps] 9-8-8 dialing when an outside line access 
code (9) is being used


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It shouldn't be much different than 911.  9911 and 911 can both work just as 
9988 and 988 can both work fine with most any PBX that can translate dial plan 
digits.

There is potential conflict with systems that can't handle inter-digit timeouts 
to allow both 988 and 9888-555-1212, I guess.  But in that case I suppose the 
expectation would be to dial 9988 and 9911 already..
Brandon


On Fri, Jul 15, 2022 at 8:10 AM Zilk, David 
<david.z...@cdk.com<mailto:david.z...@cdk.com>> wrote:
How are folks dealing with allowing calls to 9-8-8 when an access code of 9 is 
used. Does this not cause a conflict when calling toll free numbers beginning 
with an NPA of 88x?

David
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