It's been that way much of training camp, and the situation didn't change during the team's preseason opener against the New England Patriots.
McCown strengthened his case for the No. 2 spot by completing all seven of his passes and producing 10 points in a 13-10 victory on Friday night. Gradkowski led the game-winning field-goal drive in the fourth quarter, but didn't play well enough to improve on his third-string status.
Simms, fourth on the depth chart after losing his spleen and missing most of last season, didn't get off the bench.
He's been throwing since December, but is struggling to regain his form and challenge Jeff Garcia for the starting job that Simms held for much of 2005 and the first three weeks of the 2006 season.
A sore elbow has cost him practice time, and head coach Jon Gruden stressed the fifth-year pro won't get a chance until he's earned playing time.
"He has got to play better. We can all talk about the elbow and the arm, but he isn't playing very well right now," Gruden said.
"McCown is outplaying him and Bruce is outplaying him. I want him to play better. I want to move the ball and make yards, and I want to score points. When we start seeing that on the practice field, we will start playing him. That isn't happening now, and that's one of the reasons we aren't playing him," Gruden said.
McCown, who didn't play last season after beginning the year on the physically-unable-to-perform list, led a field-goal drive against New England's first-team defense and then threw an 11-yard touchdown pass to Paris Warren that finished a 10-play, 69-yard drive.
Gradkowski, who started 11 games as a rookie after Simms was injured in September, played most of the second half and completed 6 of 11 passes for 50 yards. Fourth-string running back Kenneth Darby made his job easier, rushing for 77 of his 84 yards after halftime.
"McCown opened my eyes. ... It's a good start going 7-for-7, regardless of who he's playing against," Gruden said after the fourth-year pro's first game action since the 2005 preseason.
McCown, obtained from Cleveland in a 2005 trade, injured his knee during the 2006 offseason and spent the preseason and first seven weeks of the regular season on the PUP list. He returned to the active roster in November, but did not play.
"The thing we like about Luke is his mobility. He has been on the rise since he's returned from the knee injury," Gruden said. "He missed all of last season. Had he performed like this last year, he would have been our starting quarterback, no question about it."
For McCown, it just felt good to play in a game again.
"It's been a while," McCown said. "I've gotten a lot of work in practice, but there's nothing like playing."
Copyright 2007 by The Associated Press. All Rights Reserved.