However, despite the drop in his performance level, the Manchester City goalkeeper remains England's best and should play the World Cup qualifiers against Montenegro and Poland.
This week's trendy pretender is Celtic's Fraser Forster, who put in an admirable display in the 1-0 defeat to Barcelona on Tuesday.
He's already been in the senior England squad and you can make a strong case for him to win his first cap. Just not in the two most important matches of this World Cup cycle.
The weight of playing in nets for England has brought down enough keepers for us to know that gambling on an uncapped upstart for two vital games is a bad idea.
Once upon a time, Carson enjoyed a similar positive profile to Forster. So did Paul Robinson, Chris Kirkland and Robert Green. None of them proved an adequate long-term option (Robinson stuck around for 41 caps, but found himself displaced by a superannuated David James).
How would Forster respond to the intense pressure? We don't know. He might handle it, he might not. And there's something enticing about the guy who hasn't yet had a chance to blot his copybook.
Where once Hart was overrated, he has now swung the other way. He has reached a stage where he simply cannot win. His every move is so scrutinised, every small flaw so comprehensively picked apart (his 'blunders' against Bayern weren't actually that bad), that we are tempted to declare him a busted flush.
The truth is - despite his regression - he remains a good goalkeeper with a tendency to throw in the odd clanger.
Let's return to that phrase - high-profile mistakes. Every game Manchester City play is high-profile, and Hart cannot get away with a single slip.
While it would be absurd to suggest nobody watches Celtic's domestic fixtures, the Scottish Premiership does not provide the same intensity of spotlight. How many England fans south of the border have ever even watched Forster in a league game? And if they did, how would they feel about the quality of opposition?
Plus Forster is afforded the luxury - as Hart once was - of being a player on the rise, whose positives are accentuated and negatives eliminated.
It's also true that Forster has played well on the biggest stage club football can offer, the Champions League, albeit from a small sample size of 10 games in the competition proper.
But his excellent display against Barcelona is no more proof of superiority than was Hart's man-of-the-match performance against Borussia Dortmund last season.
Forster is now the man in form, and managers are supposed to pick teams on form - or so we are told.
Only they shouldn't. You're not picking based on past performance, but on your expectation of future performance.
The only criterion that matters when a manager makes his selection is this: who is going to give me a better chance of winning?
Which goalkeeper gives England the best chance of winning? Joe Hart. God knows he's not perfect, but he's still the best we've got.
(Photo: Fraser Forster trains with England)