You do not have to just guess, if panorama is above the version of code on the firewalls it will be able to manage without any major issues. One thing I noticed is that NTP server configuration is different on the 6.1 code version, so it will register that all devices are out of sync. I was able to commit via panorama without issue to 6.0 devices despite the NTP discrepencies.
Possible that the configuration change was a feature not supported on the older version. We manage a decent amount of devices with Panorama so inevitably we have firewalls on different versions until they can all be updated during change windows. We have not seen any issues with backward compatability.
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