Rank is not a consideration. AR 600-8-2 paragraph 3-4 states:
It is the responsibility of any individual having personal knowledge of an act, achievement, or service believed to warrant the award of a decoration, to submit a formal recommendation into military command channels for consideration. The Army does not condone self-recognition; therefore, a Soldier may not recommend himself/herself for award of a decoration.
3–4. Who may recommend
a. The recommending official must have been senior in grade or have first-hand personal knowledge of the event, at the time of the action(s) or service, to the individual being recommended for an award. Additionally, the recommending official must have knowledge of all of the action(s) or service cited. That is, the recommending official must have either observed the actions or been provided information by an individual who observed the actions.