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Penrith halfback Nathan Cleary says NRL players are going to continue to emphasise or exaggerate injury for as long as it earns their team crucial penalties.

Penrith halfback Nathan Cleary says while NRL players know they can win penalties by exaggerating or emphasising injury, they'll continue to do it.

Saturday's semi-final between Parramatta and Penrith contained arguably one of the most blatant examples of a player staying down to earn a penalty when Eels winger Blake Ferguson clutched at his neck after a tackle from the Panthers' Mitch Kenny.

Almost as soon as referee Ashley Klein blew his whistle, Ferguson jumped to his feet to confront Kenny, the push-and-shove ending in several players from both teams coming together.

The NRL has already warned players this season they could face a contrary conduct charge for attempting to gain advantage with a referee for high contact.

Ferguson was not charged by the NRL judiciary on Sunday, however, with Marata Niukore the only Eels player facing a ban - for his careless high tackle on the Panthers' Scott Sorensen midway through the second half of the bruising clash in Mackay.

Cleary said Ferguson was acting no differently to any other NRL player who has witnessed the outcome of making sure high contact or crusher tackles are noticed by on-field officials.

"That's something that ultimately would be nice to be eliminated but if it keeps going like that everyone's going to do it because at the end of the day you want to win," Cleary said.

"Getting penalties helps you win so it's just the way it is at the moment.

"You watch it every week, if someone goes down and they get put in an awkward position, they hold their neck and more often than not it's a penalty.

"Again it comes back to just wanting to win the game and those things help."

The Eels, meanwhile, were fuming after the match for a different reason, with coach Brad Arthur accusing the Panthers of using trainers to deliberately slow the game in the dying minutes as Parramatta pushed for a match-winning try.

Kenny was again involved, staying down after his ankle had been stepped on, with a Panthers trainer getting play stopped by Klein just as the Eels were firmly entrenched inside Penrith's 20m.

Kenny was eventually replaced by Tevita Pangai Jnr with the break allowing Penrith to reset their defensive line and repel the Eels' raid.