Before starting the game, go to Options and turn off fatigue. Then, using two controllers, have the defense line up in a “Field Goal Block” every time. Have any receiver run a straight route or a screen pass and hike the ball. Toss the ball to the receiver and immediately have him run out of bounds. Do this 20 more times with the same receiver. It’s best to call a hurry-up offense so that the receiver is in the line up every time.
If you have only one controller, use the same method as “Deadly Accurate” but make sure you use only one player.
Achievement unlocks at the end of the game.