That is absolutely silly. If you can string two words together, you can get hired by Textbroker. I don't know about some of the other services (eHow turned me down, those sons of bitches), but once you get a feel for what kind of articles they're looking for, you can send in better writing samples for what they're looking for. Hint: it's neither academic nor creative prose. :oP

DM me if you have any questions, though I am far from the expert.