While minis on a map or terrain would make it easier, I don't think they are required. In TotM, a lot of the time you can assume that the PCs are on one side and the enemies on the other. A shooter in the back could then assume the enemies have a half cover. The player could then state they move to get a clear shot. This might require leaving their on cover. In other cases, the DM or player could state that they are cutting off the target from the shooter. This could be a situation where one or more orcs try to surround or cut off a PC from the rest of the group. The shooter then can fire freely because the target orc is on their side of their ally.Yeah, I found it after 'shooting into melee' didn't bring up anything.
'a target has half cover if an obstacle blocks at least half of its body. The obstacle might be...a creature, whether that creature is an enemy or a friend'
Which isn't an overall 'shooting into melee' penalty, it only seems to apply if the cover-to-be is directly between the shooter and the target.
Which requires a grid and minis to keep track of, so you know.
As a side note, using minis and a map or terrain does not require a grid. I make a lot of my own terrain, and it does not have a grid. We use measuring sticks marked in 5s at 1" intervals on the stick. The last session, nobody even asked for one of the measuring sticks. Everything was eyeballed.