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Yes, in my opinion.

Other things being equal, the rate of heat loss from a human (or Neanderthal) depends on surface area. (You mention brain sizes but if that is in the expectation that a larger than average proportion of heat is lost through the head, of a naked person, that is a myth. Actually it could be a little less, because of hair.)

The surface area of humans is impossible to determine accurately merely from weight and height. Other factors are involved, e.g. "heavy bones" and pot bellies, however the difference between 200 lbs at 4' and 140 lbs at 5'6" is of the order of 10% (there are calculators on the web).

40-50,000 years ago there were long periods (many centuries at a time) where the annual average European temperature barely rose to the freezing point of water.

Based on Bergmann's rule, a *"dwarved-down" Neandertal* is **more** likely to require clothing in a cold climate than a 'standard-sized' one.