I've never tried it, but I'm sure you can do it. But your ques leads me to beleive you're not looking at the situation properly.
How you define the passed data is not a concern. You can pass a table as an 01 or 05 level without an occurs. It's only important that the pgm that receives the data defines it w/an occurs clause. For example:
05 ent pic x(010) occcurs 5.
01 w-data pic x(050).
call pgma using tbl.
05 my-ent pic x(010) occurs 5.
proc div using my-tbl.
The Caller pgm could have also sent you w-data. So long as the data was organized as a table it would have worked for you too.