The EPA mpg business is strange.
It seems that in the 1990s it was pretty easy to match or beat their highway MPG.
A few years ago they revised the test to 80mph with AC on, so the numbers dropped. But despite still driving 70-75mph on the highway, it is no easier to beat their numbers with modern vehicles.
BBDartCA mentions some good variables they need to include, like grades and fuels, but they need to include those in the real tests (not just add in a fudge factor) because some vehicles are designed for great mpg on a flat road (for ex) but go down the tubes in hilly terrain because their super-tall gearing makes the automatic transmission controller unlock the TCC for every incline.
I know at 75mph with cruise control on my wife's 2009 Hyundai Sonata will unlock the TCC and shift down a gear (think near 4,000rpm) at the start of most inclines around here, and these are not mountains. I think the idiotic "grade logic" programming is to blame as much or more than the tall gearing. I wish I could disable the angle sensor.
If the EPA highway MPG test course were moderately hilly, the automobile manufacturers would probably more careful about this kind of idiocy. Their poor programming not only increases fuel consumption, it also increases wear on the transmission, and makes the ride aggravating.