A strong statement yes for sure. But some teams couldn't compete with the better teams even if they wanted to, at this stage, so they couldn't take advantage of that incentive.
In my opinion the fairest, would be to add 2020 record to 2019 record to determine the order. This way, even if you wanted to do the reverse standings, you subtract from 2019 instead of adding it, and it wouldn't take advantage as much of the awful teams.