The Rams are in 16th place ahead of hosting Neil’s men at Pride Park and are somewhat in transition.
Frank Lampard left for Chelsea in the summer, with former Holland international Phillip Cocu now at the helm.
Mason Mount, Fikayo Tomori and Harry Wilson were all on loan at Derby last season and helped them reach the play-off final.
Mount and Tomori are now regulars under Lampard at Chelsea, with Wilson having been loaned to Bournemouth by Liverpool.
Neil said: “Derby have lost a lot of loan players and if you lose the quality of Harry Wilson, Mason Mount and Fikayo Tomori it is always going to be a problem.
“I’m not sure in the long term how good it is for a club to have players on loan.
“You have a group of players who get you to a good level but after the end of a season they aren’t going to be there.
“Then you need to rebuild and restructure.
“It has been hard for Phillip Cocu going in there, it is difficult to replicate when players have gone.
“I’m pretty sure that if he had the same players Frank did last year, Derby would be doing well in the league and be quite high up.”
Despite the Rams being further down the table than envisaged, Neil predicts it will be a tough game tomorrow.
Four of their five league wins this season have come at home.
Neil is also an admirer of how well Derby retain the ball, something the statistics back up.
“They have still got a lot of good players,” said Neil.
“I have watched a lot of their games because other teams I have been studying have played against Derby.
“They are good on the ball – after Fulham they are the best team with the ball in terms of you trying to get it back off them. They are the second best at retaining it.
“We know what their strengths are and we’ve been looking at those.
“Their manager coming over from another country is having to adapt to what English football is like and that can take time.”
Derby’s last outing before the international break saw them beaten 1-0 at local rivals Nottingham Forest.
However, they won their last home game 2-0 against Middlesbrough.
Tom Lawrence scored both goals that day and is the Rams’ leading scorer with five goals in the Championship.
Martyn Waghorn is next in the scoring chart with four goals, while Chris Martin has three. Derby’s left-back Max Lowe was on North End’s radar in the summer.
They put in a bid for the 22-year-old who spent last season in Scotland on loan at Aberdeen.
Brentford were interested too but Lowe stayed put and has established himself in the Rams side, making 11 starts and one appearance from the bench.