The Raiders receiver, who earned a 99 rating in the 2019 version of the game, didn’t get a 99 this year. Of four 99s in all, only one plays offense: Texans receiver DeAndre Hopkins.
To the extent that the cover athlete gets extra consideration, that courtesy didn’t extend to Chiefs quarterback Patrick Mahomes. The reigning NFL MVP didn’t get a 99.
Last year, Madden had seven 99-rated players; Donald is the only holdover.
The ratings rise and fall throughout the season. One or more of the four 99s could go down as the game updates its numbers based on actual performance, and Brown in theory could go up.
The fact that he has publicly complained about being shorted by EA in his payment for being on the cover of last year’s game could make that a little more difficult, however.