You've heard the phrase "win and in" for advancing into the postseason. There's another, less known saying: "not play and stay."

The second one could apply to Ohio State and Michigan when it comes to the College Football Playoff.A difficult and precedent-setting call was all but guaranteed by the Buckeyes' thrilling triumph over the Wolverines in double overtime on Saturday in a battle between the second- and third-ranked teams in the CFP poll.When Penn State defeated Michigan State later in the day, the Buckeyes were shut out of this week's Big Ten championship game that will pit the Nittany Lions against Wisconsin. Both stand 10-2.But the Buckeyes check more boxes than either Big Ten finalist with a better record at 11-1 and a higher CFP ranking.Ohio State won at Wisconsin in overtime but lost at Penn State by a field goal. It could be argued that the Buckeyes have a more impressive collection of victories than either team, including the three-touchdown victory at Oklahoma in September.A case can also be made for Michigan, at 10-2 with victories over three division champions - the Badgers, Nittany Lions and Colorado - this season. We'll see where they land with Tuesday's CFP ranking announcement.Ohio State and Michigan won't be conference champions. Is the committee willing to go there - select its first at-large team at the expense of a league champ?Or will the committee select two teams from one conference, which would also be a first, and deny two conference champions?Let's say Washington defeats Colorado to win the Pac-12, Oklahoma beats Oklahoma State to win the Big 12, and Alabama and Clemson win the SEC and ACC championships.Top-ranked Alabama is a lock, and Clemson seems safely in, but the committee would have four or five teams to consider for two spots. Three of those teams would be conference champions, and Ohio State could end up being the highest ranked of the group with Michigan not far behind.The Big Ten situation is similar to what the Big 12 heard when the CFP started. Because the Big 12 didn't have a conference title game, its teams played one fewer game than the champion of the other power five leagues, and a new term was coined. The Big 12 lacked a "13th data point."This was cited in 2014 when on the final day of the regular season, TCU and Ohio State won in blowout fashion, but the Horned Frogs, ranked third in the next-to-last CFP poll, fell to sixth, and the fifth-ranked Buckeyes, whose big victory came over Wisconsin in the Big Ten title game, jumped to fourth in and into the playoff.It's also why the Big 12 has announced the return of a championship game, starting next season.Ohio State or Michigan in the CFP will mean a team will be rewarded without taking a title game risk - advantage by not playing - and that has to be part of the discussion when the committee meets. If Penn State wins the championship, it will have hoisted the trophy and beaten the Buckeyes. Its case for inclusion also will be a conversation starter.The bottom line is this: The system for identifying a national college football championship has improved over time, from polls to the bowl alliance and coalition to the BCS and now the College Football Playoff. The sport is closer than ever to a fair process.But as long as it is possible for teams to access the semifinal bracket in unequal ways - by not winning a conference title game or teams playing more conference games - and judgment is involved in selecting the bracket, the door will remain open for questionable calls and controversy.