In this technical note, we present a new theoretical result for multi-cell non-orthogonal multiple access (NOMA). For multi-cell scenarios, a so-called load-coupling model has been proposed earlier to characterize the presence of mutual interference for NOMA, and the optimization process relies on the use of fixed-point iterations across cells. One difficulty here is that the order of decoding for successive interference cancellation (SIC) in NOMA is generally not known a priori. This is because the decoding order in one cell depends on interference, which, in turn, is governed by resource usage in other cells, and vice versa. To achieve convergence, previous works have used workarounds that pose restrictions to NOMA, such that the SIC decoding order remains throughout the fixed-point iterations. As a comment to the previous works, we derive and prove the following result: The convergence is guaranteed, even if the order changes over the iterations. The result not only waives the need of previous workarounds, but also implies that a wide class of optimization problems for multi-cell NOMA is tractable, as long as that for single cell is.