Medicaid answer

Need: brief written opinion from a licensed U.S. attorney with healthcare fraud-and-abuse / Anti-Kickback Statute experience (Louisiana a plus). I run a company that provides claims-recovery services to home-health and behavioral-health agencies. The agencies bill Medicaid (some VA, some commercial). I do not bill any payer directly — the agencies pay me out of their own funds for my service, and no payer funds are ever assigned to or held by me. I want to pay an independent marketing/business-development consultant (not an employee) who introduces agency clients — businesses, not patients — to me. I'd pay him a percentage of the service fees I actually collect from clients he refers. Question to answer: Is that percentage compensation permissible under the federal Anti-Kickback Statute (42 U.S.C. §1320a-7b), EKRA (18 U.S.C. §220), and Louisiana law — given that (1) I don't bill any federal program directly, (2) no payer funds are assigned to or held by me, (3) the fee is a share of my service revenue, not a payer payment, and (4) he refers business clients, not patients? Specifically: can the percentage apply to clients whose recoveries are Medicaid/VA, or must federal-program-derived compensation be a flat fee set in advance? What structure keeps me compliant? Deliverable: a short written answer (a few paragraphs) — yes/no on the percentage for Medicaid/VA, the reasoning, and the safest compliant structure. Please confirm your bar license (state + bar number).