To'o was put on report for a high shot on Canterbury centre Bronson Xerri late in the Panthers' 8-6 win on Thursday night.
The initial contact appeared to be on Montoya's chest, before To'o's shoulder appeared to bounce up and connect with the lower part of the winger's face.
To'o has a clean record and would be able to escape with a fine if hit with a grade-one charge by the match review committee for the tackle on Friday morning.
But a grade-two offence would spell trouble, given it would be enough to have him banned for the Origin series decider at Accor Stadium on July 9.
Asked if he was worried about the tackle as he left CommBank Stadium on Thursday night, To'o replied: "Nah".
He added: "I asked him if he was alright, he said he was sweet.
"But I had to check on Brons and see if he was alright."
Penrith coach Ivan Cleary and Canterbury counterpart Cameron Ciraldo both played down the tackle.
The bigger issue for To'o could be his left knee.
The 26-year-old confirmed after the match he had suffered a fresh issue when he required strapping to it in the first half, and he left the ground with ice around it.
To'o's fitness is crucial for NSW, after his sheer power helped him score a hat-trick in the Blues Origin II loss in Perth.
"I'm still walking, that's the main positive sign," To'o said.
"I think it might've happened during the game, either way I'm all good ... It's good."
To'o did finish the game, but also did likewise when he hurt his hamstring in round four before being ruled out for five weeks.
"I'm not too sure. He kept playing, but I have seen him do that before," Panthers coach Ivan Cleary said when asked about how To'o was.
"I honestly don't know how he is."
If To'o was to miss, Canterbury winger Jacob Kiraz would loom as the most likely replacement.
The good news for NSW was with Nathan Cleary after hearing his groin pop on the day before Origin II in Perth.
The Penrith halfback didn't kick goals in the win on Friday night, and remains unsure if he will be able to do so in the decider.
But crucially, he got through Thursday night unscathed.Â
"It was good, I didn't really have any scares at all," Cleary said.
"This week I got two really solid training sessions in and felt confident. I am very grateful to the NSW physios and Penrith physios.
"They put a lot of work into me and got me into a headspace where I was right to play.
"Goalkicking is the next box to tick, but I was happy with how it went."
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