Even temperatures in excess of 20 C (68 F) can occur over snowpack - for example in much of the Upper Midwest and Northeast US during the March 2012 anomalous warmth event. Along the U.S. - Canada border, several places such as Marquette, MI and Caribou, ME did this at some point from March 18-21.
That said, a large enough ice-covered body of water does chill the air, as mentioned earlier, there is nothing like trees or buildings poking above to catch the sun and heat far above the freezing point. A small lake may not do it much, but try being on the immediate downwind coast of Lake Michigan or Lake Superior when it is covered with ice...
Hudson Bay is perhaps the most extreme example of this effect. On some early summer days, the high temperatures in the surrounding land areas can easily reach 25C/77F far from the bay. But 2m temps, looking at NCEP/NCAR, are held within a few degrees of freezing over the central portion of the bay, even when the surrounding land areas are far, far warmer. GFS and NCEP/NCAR both show some area with air temps below 2 C somewhere on Hudson Bay, as long as there is ice. I have not seen a single exception, even when portions of Ontario are suffering from sweltering heat of 30-35 C!