Analog Endpoints and Cloud Calling

Every cloud calling migration reaches a meeting where someone asks about the elevator phone. It is usually late, it is usually asked by facilities rather than IT, and the honest answer is usually that nobody has looked.

Analog endpoints are the most reliably underestimated part of a migration to cloud calling. They do not appear in a user count. They are not in the phone system's device list in any useful way. Several of them are life-safety equipment with code requirements attached. And they are frequently the reason a cutover date moves.

The short answer

Analog endpoints do not migrate. They get re-homed onto new hardware, replaced, or left on a dedicated line — and each of those is a different purchase with a different lead time. The work is not technically difficult. It is an inventory problem, and the only expensive version of it is the one you do after the cutover instead of before.

Count analog during discovery. Give it an owner. Treat any device involved in life safety as a separate workstream with the local authority having jurisdiction in the loop. On the collaboration and unified communications projects we run, this single inventory is the difference between a cutover weekend that finishes on Sunday and one that does not.

What is actually hanging off your phone system

A representative list from mid-market and enterprise sites. Most organizations find more than they expected, and almost nobody has a current list:

• Fax machines — accounting, HR, legal, and anything that touches healthcare or public sector workflows, where fax is often still the mandated transport
• Elevator emergency phones — code-mandated, usually one per car
• Area of refuge and stairwell emergency phones
• Gate, door and lobby intercoms
• Overhead paging and bell systems — schools, warehouses, plants
• Fire alarm panel and burglar alarm dialers
• Credit card terminals and legacy modems — including building management, HVAC controllers and older medical or lab equipment
• Courtesy phones — lobbies, loading docks, parking structures, break rooms
• Conference room speakerphones on their own analog extensions
• TTY/TDD devices where accessibility obligations apply

The pattern to notice: the majority of that list is not owned by IT. It is owned by facilities, security, EHS or a line of business — which is exactly why it does not show up in an IT-run discovery, and why it needs to be asked for explicitly.

Three ways to re-home an analog device

Most sites end up with a mix of all three. That is the correct answer, not a compromise — the failure mode is picking one approach for everything.

Fax deserves its own decision

Fax over IP is the single most common source of post-migration complaints, and it is worth being blunt about why: fax was designed for a circuit-switched network and packet networks handle it imperfectly. Cisco's own guidance for its ATAs says so plainly:

"Data devices, such as facsimile machines and modems, may not function optimally. For the best fax and modem performance, continue to use a dedicated PSTN line."

— Cisco, Get started with your Cisco ATA 191 and 192

The same documentation advises connecting the fax machine directly to the ATA with no extension or splitter, and lowering the transmission speed — or using overseas mode — to reduce failures.

So decide deliberately, per machine:

• Does it still need to be a fax? A meaningful share of remaining fax volume in most organizations is habit rather than requirement. Cloud fax or a secure document exchange removes the problem entirely.
• If it must stay physical, is it high volume or occasional? Occasional, low-speed fax over an ATA is usually acceptable. High-volume or contractually-guaranteed fax is not something to gamble on.
• Is there a compliance requirement — healthcare records, legal service, government submission — that specifies the transport? Confirm before you change it. In regulated environments this is a governance, risk and compliance question before it is a telephony one.

Life safety and emergency calling: the part with legal weight

Two federal rules apply to multi-line telephone systems in the United States, and analog endpoints are squarely inside them.

Kari's Law requires that users can dial 911 directly, with no prefix or access code, and that the system notifies a central on-site or off-site location when a 911 call is placed. The requirements apply to systems manufactured, imported, offered for first sale or lease, first sold or leased, or installed after 16 February 2020. A migration is an installation.

RAY BAUM's Act, Section 506 requires that a dispatchable location — street address plus the detail needed to find the caller, such as floor and room — is conveyed with the 911 call. The compliance dates were 6 January 2021 for on-premises fixed devices and 6 January 2022 for on-premises non-fixed and off-premises devices.

What that means in practice for analog:

• Every analog port that can dial out needs a location record specific enough to dispatch to — not just "the building."
• An ATA that gets moved to a different floor without its location record being updated is a compliance gap, and moves happen constantly.
• Notification has to go somewhere a human will actually see it. Deciding where is a business decision, not a config setting.

Elevator phones carry an additional layer. ASME A17.1 governs two-way emergency communication in elevators, and requirements have expanded in more recent editions. Which edition applies to you depends on what your jurisdiction has adopted, so confirm with your AHJ and your elevator maintenance contractor before you change how that phone connects. This is not a decision to make on IT's own authority.

The copper problem sitting underneath all of this

"Just keep it on a POTS line" is the easy answer for life-safety devices, and it is getting harder every year. Carriers are actively retiring copper facilities, and the FCC opened a proceeding in August 2025 proposing to streamline the section 214 process by which carriers discontinue legacy services. That proceeding is a notice of proposed rulemaking rather than a final rule — but the direction of travel is not ambiguous, and pricing on remaining lines already reflects it.

The planning consequence: treat every retained POTS line as a temporary position with a cost that rises, not a permanent solution. Purpose-built POTS replacement products exist — typically a cellular-backed device with battery backup and line monitoring — and they are usually the right answer for elevator and alarm circuits. Verify that whatever you choose is accepted by your AHJ and your alarm monitoring provider before you order.

Where this goes wrong

1. Analog is counted during cutover week. By then the ATAs are not ordered, the gateway is not sized, and the only remaining option is to delay.
2. Somebody unplugs a line that turns out to be the fire panel dialer. Alarm dialers are silent until they are needed. Coordinate with the monitoring company and test after the change — an untested alarm circuit is worse than an obviously broken one.
3. Location records are set once and never maintained. Emergency location data has to be part of your move/add/change process or it decays within months.
4. Fax is assumed to just work. It sometimes does. When it does not, it fails intermittently, which is far more disruptive than failing outright.
5. Nobody asked facilities. The single highest-yield thing you can do in discovery is walk the building with the facilities manager and open the comms rooms. You will find punch-down blocks with pairs that nobody has documented since the building was fitted out.

The inventory to build

One row per analog port, before design starts. These columns are enough:

Expect to retire 20–40% of what you find. Devices outlive their purpose quietly, and a migration is the only time anyone looks. That alone often pays for the discovery, and it is a standard part of our implementation and migration scoping.

If you are scoping this alongside a platform move, the wider sequence is covered in what a CUCM to Webex Calling migration actually involves.

This article describes technical and planning considerations and is not legal or code-compliance advice. Confirm emergency communication requirements with your local authority having jurisdiction.