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In addition to being used in college football due to the lack of playoffs, the term is also used in college basketball prior to the introduction of the NCAA Division I Men's Basketball Tournament. Prior to the NCAA Tournament's establishment in 1939, there was no way to legitimately determine a national champion, and so any team that claims a national championship prior to that year is probably claiming the title from the Helms Athletic Foundation(no relation to Jesse Helms), which founded in 1936, decided on a national champion each year(in years where the NCAA Tournament is held, it almost always agreed with said tournament), and retroactively decided on champions all the way back to 1901. For example, despite winning only four NCAA Tournaments, UNC also claims to be the national champion in 1924, allowing them to claim to have won five.