If Qualcomm cared they could do the same thing. That's gigawatts of energy, over billions of cellphones, being wasted by modems because the vendor doesn't care.
The problem, of course, is the cost of that inefficiency is external to the vendor.
Maybe Qualcomm will improve their power performance in the next-next-generation.
How so? The impact of power efficiency is arguably as immediate to a mobile phone manufacturer as it gets. These things are battery powered, and many people are struggling to make it through a single day on one charge!
Of course, that's practically exactly what battery size is tuned to – making it through exactly one day for most users. Knowing Apple, they'll just make the next flagship half a millimeter thinner again rather than risking one and a half days of battery life...