No...the whole point is that the single instruction induced halt for downclocking isn't a real issue. Even in the pathological case where you insert a single instruction spaced 760 us apart in order to induce the maximum number of clock shifts, the total performance degradation due to the clock halts is only 3% (the frequency drop that is induced by the use of these instructions has a much larger impact.) Furthermore, on Icelake-SP, the halted time due to frequency transitions is supposed to go to 0, which makes this aspect of the problem entirely irrelevant.

Yes, if you insert a single 512-bit FMA that runs every so often in your code you will get a 15% performance hit from the lower frequency, but that's much less likely than the old case where people who were trying to use AVX-512 for memcpy and the like would slow down scalar code.