Bears quarterback Jay Cutler was checked by trainers after he took a late hit Sunday night by Texans linebacker Tim Dobbins. Cutler later left the game with a concussion. (AP)

The return of Chicago Bears quarterback Jay Cutler will be no simple process.

For one, Cutler can be categorized as a player who has a history of concussions. The concussion Cutler suffered against Houston Sunday night is his third since coming into the NFL. He had one with the Broncos in their 2006 season finale against San Francisco, another in 2010 with the Bears against the New York Giants, and then one Sunday in the game against the Houston Texans.

According to the Tennessean, Cutler also suffered three concussions while at Vanderbilt before coming into the NFL in 2006, although this is difficult to verify.

The Bears let LB Hunter Hillenmeyer go after 2010 due to a series of concussions he suffered.

"If we error, it will be as far as keeping players out longer," coach Lovie Smith said Monday. "We do have a history with players, we have a history with Jay, Hunter Hillenmeyer, we have a couple guys and every football team has players who have gone through concussions -- but not just a concussion. We do that with all of our players with any injury that they have.

"We’ll never put a guy at risk. No game is that important for us. Of course, the players’ health always comes first with everything that we do."

Smith did say Cutler seemed better by game's end Sunday but could offer no timetable on his return.

The NFL policy on concussions says: "Once removed for the duration of a practice or game, the player should not be considered for return-to-football activities until he is fully asymptomatic, both at rest and after exertion, has a normal neurological examination, normal neuropsychological testing and has been cleared to return by both his team physician(s) and the independent neurological consultant."

Cutler had to wait a week for symptoms to clear before he could return in 2010 to play against Detroit after missing a game against Carolina following the concussion he suffered against the Giants.

While Smith took the high road with his team's policy about concussions, there was immediate criticism during the game and then again Monday over the way Cutler was allowed to leave the field but then returned after being examined.

Smith said the hit Houston LB Tim Dobbins made while Cutler was throwing on the run -- which drew a 15-yard penalty for Houston -- was the one the Bears believe caused the concussion and that normal protocol for dealing with possible concussions was followed.

"Right after that, we had a break since the play was being challenged," Smith said. "Our trainers talked to him then. ...  It's not like he showed symptoms, but he had a break in between. Our trainers talked to him, evaluated him, he was fine from there. Players in the huddle didn't see anything wrong with him at the time."

Trainers and doctors talked to Cutler, and he returned for seven plays after that series had ended.

"Jay is a tough guy, if he was hurting, he wouldn’t tell us," WR Brandon Marshall said. "When he was in the huddle, everything seemed normal."

Cutler threw an interception into coverage at the Houston 27 with the Bears owning the ball at Houston's 39. He also scrambled the ensuing series for 19 yards.

"So, and not just then, we continued to talk to him all the way out through even to the halftime," Smith said. "When I say normal protocol for a concussion, that's what I'm talking about. We were constantly talking with him. And if you look at his play, it's not like he was light on his feet or starry eyed or anything like that.

"We felt like he was in control of everything, just like the rest of our players at the time."

Another concussion sustained by rookie DE Shea McClellin was more obvious "right away," Smith said, adding that it "really kind of hurt our (D-line) rotation a little bit."

McClellin also has a concussion history. He had two while playing at Boise State.

Follow Bears reporter Gene Chamberlain on Twitter @CBSBears.