The 23-year-old has not played for Ireland since the summer tour to North America - from where he was seconded by the British & Irish Lions - having broken his foot in October and missing the subsequent autumn tour.
He was named in Ireland's training squad and was on the bench for the Wolfhounds' victory over England Saxons but against Scotland and Wales, Schmidt opted for Andrew Trimble and Dave Kearney on the wings with Fergus McFadden covering.
Two wins from two would suggest Schmidt may stick with what he has but Penney is convinced Zebo can force his way back into the reckoning.
"Zeebs is in a great space. Zeebs is a fantastic bloke and he needs to be embraced for what he is. He's not your quintessential rugby man, and you'd never want him to be," he told the Irish Independent.
"Zeebs is loving the football, and that's all you ask of your players. No matter what jersey they put on, as long as they're loving what they do, they're going to get a performance, and if they get selected for the next team up - whatever that may be - on the back of loving the game and doing the right thing and the jerseys on the way up, that's all you can ever ask.
"So, for Zeebs, he understands that. He just loves being at Thomond Park in front of the Munster crowd. They embrace him for who he is.
"He's in a good space and there's some challenges for him to get back in the Irish team, and he knows that. And the only thing he can do is perform outstandingly well.
"He's coming off a long injury that could potentially be very niggly. He's done the right thing rehab-wise, got himself in really good shape physically, returned at a time when the foot shouldn't be an issue going forward for him and now he's just got to be consistent on and off the field to prove to other people that he's ready to be an international footballer."