The NHTSA is tired of Tesla's hand-waving away their safety investigations into Autopilot by pushing stealth updates that fix specific scenarios in specific places being investigated. NHTSA wisened up to that and independently purchased their own Tesla vehicles, and disabled software updates, so that they can reproduce those scenarios themselves.
If NHTSA asks Tesla to provide system validation tests showing that an updated version of their software meets the design intent of the system, Tesla would not be able to do so. If they can't prove the new Autopilot software corrects the safety-related defects identified in the current version, then it's not a valid recall remedy.
All evidence from their own AI/AP team and presentations is that there is no real design and system validation going on over there. They're flying by the seat of their pants, introducing potentially lethal regressions in every update.