Simmons (elbow) is inactive for Monday night's game against the Dolphins.
Simmons, who was doubtful for the contest, will now target a possible return to action Sunday, Oct. 13 against the Colts following the Titans' Week 5 bye. In three games to date, Simmons has logged 12 tackles, including 1.0 sacks, with his absence Monday representing a hit to Tennessee's Week 4 defensive line.