You may want to hire a health care consultant or attorney who is knowledgeable in this area and who can advise you on the particulars of your situation. One resource for finding such a consultant or attorney is FP Assist, a service of the AAFP. You can access this service online or by calling 800-274-2237, ext. 4148.
You may also seek an advisory opinion from the OIG. For more information, go to: http://oig.hhs.gov/fraud/advisoryopinions/aofaq.html.