I have one question for any guy who brags too much about his past accomplishments: “What have you done lately?”

The question is simple, and it implies that no matter how well someone has done in the past, it is important to maintain that success in order to stay ahead of the game. Coincidentally, it seems that New England Patriots quarterback Tom Brady has failed to maintain his success.

Brady hasn’t measured up to the competition recently, being winless in the Super Bowl since the 2004-05 season. On the surface it’s easy to criticize someone who asks what he has done lately. A big game victory has eluded him, yet he garners praise from those who became fans during his success.

Brady is proving that championships are not as important as consistency when it comes to leaving a legacy in the NFL. Last week, 26 inside sources for the league sorted the starting quarterbacks into five tiers. Brady tied for the best in the NFL, with 25 of the 26 voters placing him in the first tier, according to ESPN Insider.

But wait. He has failed to help his team reach the Super Bowl in seven of the nine seasons since 2004 and lost it during those other two. If one evaluates talent based on championships, Brady is probably a tier-3 quarterback. That would suggest there’s no hope for young phenoms who haven’t had many chances to reach the big game.

This is the crux of why Brady has endured the test of time and the harsh criticism that goes along with a career in the NFL. It’s his resilience that puts him ahead of most other quarterbacks in the league. Only Peyton Manning, Drew Brees and Aaron Rodgers are tied with him for the best spot, and each of them has fewer championship rings.

Let’s call it the Brady rule: You don’t need championships to be considered one of the best. Take a look at the other quarterback who cracked the top tier. Andrew Luck of the Indianapolis Colts is yet to reach the Super Bowl in his first two NFL seasons and has lost two out of three playoff games in that short span.

However, Luck has played in all 16 games in both of those seasons, thrown 23 touchdowns each year and cut his interception total in half from 2012 to 2013. And statistically, Luck has given solid performances with two different offensive coordinators over the course of those two seasons.

The best in the league are defined by their own performance in relation to the personnel surrounding them. Brady was named the Super Bowl MVP in both 2001 and 2003. He was the league MVP in 2007 when he threw for 50 touchdown passes during the regular season. Those are the personal accolades.

However, during the Patriots’ championship years, Brady was surrounded by a reputable defense. In recent years, he has had no such luck. He has played on teams that have featured a primary running back like Corey Dillon and BenJarvus Green-Ellis. He has also played on teams that have run the ball by committee. He had Randy Moss to dominate defense in 2007, but has not had a reliable deep threat in recent years. Tight end Rob Gronkowski has been a beast ever since he joined the team in 2010, but he has struggled to stay healthy as of late, challenging Brady to find other targets.

Seattle’s own Russell Wilson, who is fresh off a Super Bowl championship in only his second NFL season, was blessed with an incredible defense that included cornerback Richard Sherman and a running game led by Marshawn Lynch. Despite all of that, he did not make it to the first tier, despite a championship ring and consistent statistics. Why? He has not been tested by a team hardship or any sort of significant personnel change yet.

Brady’s numbers remain consistent through it all, championships or not, superstar-loaded rosters or not. He has thrown for at least 25 touchdown passes in nine of the 14 years he has been in the league, with 2000 being a year in which he did not start and 2008 being the year he missed entirely due to injury. He has never thrown more than 15 interceptions in a single year either. That reliability is slightly surprising considering the pressure Brady has endured from opposing defenses, especially last season when he was sacked 40 times, the most since 2001.

Winning Super Bowls is obviously the highest honor a team can earn, but in terms of selecting the best quarterback in the league, winning it all doesn’t automatically put a player above all.