Yeah, if your dealer has updated his diagnostic tools, FCA's current tool software prevents the tech from touching that portion of the module and they can't change the pre-programmed values.
No aftermarket tuner touches that area of the module however as 07MegaCabRam mentioned, there is a tool made by Autel (MaxSys MS906 - currently on sale at just under $1,000) that can do the TPMS reset.
I do have a reset procedure that can be used but it only works on prior versions of the FCA tech tool. You'd have to call around to see if any dealers in your area still has a prior version.