What are your thoughts on the award policy in the Army? Should certain awards be reserved for higher ranks and positions?

Granting an award is always in the hands of the approval authority. In this case, a MSM will go to your CG, or a GO/SES that they've formally delegated the approval authority to (i.e., in writing).

The only person who can deny/downgrade the award is the approval authority or, if formally delegated, an immediate subordinate commander who has the authority to approve the next lower award. In the case of a MSM, it would be the O-6 commander in the chain of command (again, if the authority to deny it has been formally delegated).

Your Company Commander can recommend it be downgraded or disapproved, but they cannot downgrade or deny it as they don't have the authority to do so.

Of course, that is how the regulation (AR 600-8-22*, para 3-6f) requires it, but awards being 'kicked back' seem to happen frequently at the lower echelons (even the higher echelons although to a lesser degree) because individuals don't know the requirements ("what do you mean I can't disprove it?") or just ignore them ("I'm not going to clog up the CG's inbox for something that is going to be denied anyways.").

I would respectfully and tactfully direct your CO's attention to the applicable paragraph. If it remains 'kicked back' (i.e., it wasn't being done because of a lack of understanding), then you'll have to decide 'if the juice is worth the squeeze' regarding further actions.
------------------------------------------
* AR 600-8-22 - https://armypubs.army.mil/epubs/DR_pubs/DR_a/ARN30935-AR_600-8-22-000-WEB-1.pdf

I hate the rank dictates medal garbage.

That said, don't sweat the downgrade. Keep performing to the best of your abilities by setting the example (like in division gunnery) and the rewards and awards will come.

Oh. Dear. God. How I hate it when Leaders use rank/position as a basis for certain levels of awards. It clearly states in the regs that this (outside very specific awards) practice is not allowed. It needs to be based on the level of impact.

I've no idea if DIV Gunnery is a level worthy of MSM, but that is NOT for your Commander to decide. That belongs to the CG or their designated rep. I don't feel the fastest ruck time is worthy. AAM at best.

Again, I HATE this for you.

No, certainly not. HOWEVER, winning division gunnery does not in my opinion rise to the level of an MSM. Top Gun in Division Gunnery is an ARCOM level award.

Your CO is close to right, but probably for all the wrong reasons, (unless he knows this and didn't want to give the complete explanation).

The reason why it looks like awards are based on rank (duty position really) is because the approving authority for an award considers the service and achievement of the awardee as it pertains to the positive effect or influence on their formation or it's mission.

In the case of an MSM, a GO is looking at the positive effect or influence on that brigade, and overall that division's formation or it's mission. A successful BN command with quantifiable improvement could very well have a positive effect on that division's mission, so you see BCs getting an MSM.

And bear in mind, every award below LOM is 4 distinct achievements to describe and justify that level of positive effect or influence, compared to an impact award which is just one very significant achievement. A good example of an impact award would be a Soldier stepping above their level of responsibility and providing the solution that no one else at BN or BDE level came up with to overcome a significant problem.

In your examples, winning the division gunnery competition, or the two soldiers with the fasted ruck time in a E3B, these would be impact situations, but definitively individual achievement, not necessarily having a greater positive effect or influence on a formation or it's mission.
Often, winning a division level competition, or even one of multiple events of an E3B, like the road march, is recognized with a coin from the CG.
Just as often, it is recognized with an impact AAM or ARCOM, but until today I have never seen an example of an impact MSM awarded in this situation, which many would argue is excessive.

SFC (Join to see) Award policy is stated in the regulation as COL Randall C. has pointed out. But, if I interpret your question correctly, it is less about, "Does DIV gunnery rise to the ranks of an MSM recommendation?" and more of "How would you set criteria for awards?"

I will preface this to say that each approving authority (and their SEL) will interpret award criteria in many different ways based on their understanding and experience.

For the former, I am with SSG Roger Ayscue, I would not advise anyone to recommend an MSM for DIV gunnery. My rationale is that it was created as an "almost" Legion of Merit to recognize exemplary service. While it can be used for specific acts of achievement, my thought is that it centers around the character of service and not one-off events such as BWC, DIV Gunnery, Best Sapper, etc.

For the latter, when advising approval authorities, I always try to initiate that conversation early in their tenure. The purpose is to understand what they envision for each award that they have approval authority for and that would pass through them as an intermediate approver. It helps to recap the scope of each award and the history (kind of our job as NCOs is to steward the history and traditions of the military). The act of reviewing awards is usually enough to center the Officer on a common sense approach that is uniform across all awards. The task is then to communicate this philosophy across the formation.

This is not to say that some people will get into their feelings about what they perceive as favoritism or preferential treatment to certain pay grades or specific awards, or bring up that one dumpster fire who got a RET award they didn't deserve that one time. It is not perfect, and there is a lot of variability across commands. In my experience for example, what one GO may think of as criteria for a Silver Star may not meet the criteria of another, and a lot of confusion happens because the expectations for each award are not communicated clearly to subordinate commands.

Certain awards ARE "reserved for higher ranks and positions" -- just no one wants to ever admit that in writing.

I have had an ARCOM kicked back because my soldier was a specialist and received one every PCS for doing less. When I submitted my retirement award to my rater, I submitted an AAM. If my soldier could not get an ARCOM then an AAM is fine for me. Still stings I received nothing at retirement but I can say one of the last things I did was stand up for an enlisted soldier.

The ARs were written for a reason, standards for the awards. There is nothing in the ARs about certain ranks for certain awards. Just too bad there are leaders who think awards should be given by rank. Get with it .

No awards should not be reserved for certain ranks, that is horse manure. But I can tell you when in Afghanistan, our commander gave all the officers bronze stars and the enlisted AA's. Yet not one officer except a LT ever went outside the wire, hell our commander rarely came to the office before 11:00 and was gone by 3:30. Never attended staff meetings for the higher command, always sent a NCO to represent our unit.