I received a response from the FCC this morning...
"We agree that you may build the device and operate without a certification from FCC. This is true since the module you are using is already certified, and you are not changing the design that affects the RF specifications.
Also since you are not manufacturering this product in mass quantities, and intending to market to the public for sale, then the certification is not needed for this reason as well."
For reference, I had found the following two documents of direct relation to this issue.
Transmitter Module Equipment Authorization Guide