There's no telling who came up with that expression but Donovan McNabb's recent troubles in Washington demonstrate that it is still as true today as it was whenever it was first uttered. If you'll recall, there was a story that both Buffalo and Oakland called Philly to ask about trading for McNabb:
The source said McNabb likely wouldn’t sign a long-term deal in either Buffalo or Oakland, which could create a sticking point in any trade talks, as both franchises would expect a new deal in place before acquiring him.
Meanwhile, Oakland has managed to pick up more wins than Washington in spite of shoddy QB play AND Al Davis. The Bills haven't won as many games as the Redskins but arguably are playing better football. At the very least McNabb wouldn't have been subjected to the same psychological warfare in Buffalo that he has experienced in Washington.
And, no, I don't think the Bills should make a run at him in the offseason.