Mathematically, with no ties, a team could be in a 4 way tie in their division at 3-13 and make the playoffs by splitting the games in the division and losing the rest. The winner would be based on strength of schedule.
If ties were common then you could do the same with the division winner finishing in a 4 way tie at 0-10-6. Just lose all non division games and tie all division games. and once again winner goes by strength of schedule.