If the steering wheel is not securely locked in place with a stabilizer or held in place by a 2nd pair of hands it will shift slightly during the tie rod adjustment. Some guys wrap the steering in place with the seat belt, which puts tension on the wheel but Ive never seen anyone firmly lock it in place with this method. The vehicle has to be driven afterwards, meaning the shop is well aware the wheel is off center before they give it back they just dont care because most mechanics are flat rate and in their minds theyre getting paid to do a wheel alignment, not a steering wheel alignment. The shop itself should compensate their mechanaics for the final adjustment or require it as part of the service but many dont as a general policy because jt often provides them an opportunity to file an additional service claim on the return visit, especially when its a warranty or insurance claim. If they try to claim a steering wheel alignment in addition to the wheel alignment at the time of service it is likely to be denied by the manufacturer or insurance adjuster because their policy requires it as part of the alignment service. Its shady but so is the stuff that insurance companies and manufacturers pull by nickel and diming these shops. Unfortunately when you get as big as these manufacturers or insurance companies get its too easy to bully these shops into going along with whatever you say because if they say no you'll just find somebody else who is hungry enough to say yes..... long story short... everybody gets screwed except the filthy stinkin rich guy