2 Realistic ways to flip 37 votes

Biden flips MI, PA, and the NE congressional District 2.
Biden flips WI, NC, AZ, and the NE congressional District 2.

Alternatively there were 10 faithless electoral votes in 2016, 7 from states that allow them and do not invalidate them.

In a close election i could see an attempt to throw it to the House. The House can chose from the top 3 electoral vote getters. In 2016 Colin Powell received 3 electoral votes that were allowed to stand. Had it gone to the House, Powell would have been an option for state delegations