Responsibility and Competitive 8(a)

I am getting ready to identify that apparent succesfull offeror under a competitive 8(a) procurement over $3.5 million. My agency has an MOU with SBA allowing us to issue awards directly to the 8(a) company. However, the MOU requires that we give SBA 5 days to determine eligibility of the awardee. In this case, I think there may be a responsibility issue. Under an 8(a) procurement, can I request a COC from SBA or are the regulations different for the 8(a) program regarding this matter.

See FAR 19.809:

19.809 -- Preaward Considerations.

The contracting officer should request a preaward survey of the 8(a) contractor whenever considered useful. If the results of the preaward survey or other information available to the contracting officer raise substantial doubt as to the firm?s ability to perform, the contracting officer must refer the matter to the SBA for Certificate of Competency consideration under Subpart 19.6.