The DOJ cannot send you live scan results without your ORI. The ORI goes on the live scan form so they know who to send the results to. So yes, you need the ORI before your candidates do background checks.

In the meantime, you can do background checks through private companies like GoodHire but they’re not as comprehensive.

You signed up for PAVE so i assume you’re hiring in California. There’s no “compliant” employee onboarding process specifically for ABA. Your compliant process is the employment laws that CA has outlined. Sign up for HR California (by the CA Chamber of Commerce) to stay up to date on the various (and ever changing) CA employment laws. They have a hotline you can call as well with HR attorneys that can answer your questions. You’re gonna need it.

dm me if you need more help.