Exactly.
What about Marcus Levasseur, wasn't he an undefeated D3 champ?
How about the D3 kid currently on a 56 match win streak with 24 pins and techs and 100-0 takedown margin?
Plenty of outstanding guys in lower divisions, but the Hodge should be an award for those who test themselves against the best, day in and day out.
(Joe Dudek didn't win the Heisman, despite a famous SI article)