Dear Brenda, the top people at topiary do not use a frame at all! They use different size box plants to get the basic shape and then with trimming and growth they get what they want!
The frame must be removable and normally you plant the different size plants inside the frame and then trim them to the size you so wish.
The frame is removed and you have the finished product. However there are no set rules for this, but planting them to grow around the frame would make it difficult to get the frame out! Most frames are easily made from cane, especially when doing easy ones like peacocks!
Love.
Neil.