Not always the case.Ι think it's mostly aios with flat contact that need a frame. My u12a keeps my 12900k at 76c peak in CBR23 stock with no contact frame. It can also do 5.7ghz in 2 cores and 5.2ghz in all core loads (although it climbs to the low 90s in this configuration).
The Noctua NH-D15 and NH-D15S which should in theory be perfect for the bent CPU, despite good contact at the centre of the chip, wouldn't get good uniform mounting pressure here.
Using the frame allowed a uniform pressure, and considerable gains.
During the first few weeks it was fine without the mod, but after a while, the temperature increased daily.
Yes, the issue would be more noticeable with flat blocks, but even for Noctua coolers, the mod has proved beneficial. I guess that, after a while, the curvature of the CPU was greater than the cooler could compensate.