After Goforth pitched in consecutive games and threw 53 pitches, the Brewers may have opted to activate Smith a day early in order to add another fresh arm for Wednesday's series finale against the Cardinals.
Smith appeared in 154 games for Milwaukee over the past two seasons and owned a 2.70 ERA in 2015. He was named co-closer along with Jeremy Jeffress before suffering his injury while taking off a shoe in Spring Training.
Counsell said on Monday that he would prefer to ease Smith into his role in the bullpen, but is open to using him in high-leverage situations if the need arises.
"Like any guy coming off an injury, like any guy the first week of the season, that's how I treat it," Counsell said.
Goforth gave up four runs while only recording one out in Tuesday's loss.
Curt Hogg is a reporter for MLB.com based in Milwaukee.