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My guess is that it will become increasingly difficult to obtain MPG much higher than EPA as cars become more efficient in general.
In an older manual gearbox car, I can select efficient gears, DFCO, cut the engine at stoplights, etc. A newer car might come with engine stop/start, CVT, and other efficiency improvements that allow less skilled drivers to get good economy.
With my 1997 5-speed Subaru Legacy, I was able to get about 30 MPG compared to the 24 MPG EPA rating. When I bought a 2007 Outback with automatic tranny, my hypermiling couldn't get it above 25 MPG.
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