You mean any prepaid bought-in-a-pharmacy card?
Those allow any physical US address to be used as a "billing" address.
Though I suppose they could try to block prepaid cards in their billing system
Or a Netflix "gift" balance (one of those "Buy Galaxy S6 phone, get free Netflix for a year")
I presume primary way to beat VPNs are "is this a retail ISP block" and "are there more than N streaming connection request for distinct users coming from the same IP address". If both are "true" - voila, you have a VPN that is masking Netflix users.
And while VPN could theoretically get an IP address for each user, it would be quite expensive for them (for IPv6 this would also work, as you have one routable block exhibiting requests from a bunch of random users with vastly different billing addresses)