I think one thing that many quality auto journalists try to achieve with any car they are testing is consistency. The same way they test the Z06 Corvette is the same way that they test the Fusion Hybrid, the Alpha Romeo 4C, the Tesla S, Jeep Renegade, and any other model. And many auto sites look at and try to achieve the best numerated results like Top Speed, 0-60, Quarter Mile Time/Speed, and Braking Distance at 60mph. That consistency is a good thing. When driving a car aggressively most people will achieve similar results.
That constancy can be used by people that drive differently. For example Car and Driver had an observed 32 mpg for the FFH (2013). The same type of testing rated the Ford Focus (2012) at 21 mpg. As a previous Focus owner I can say that it gets WAY more than 21 mpg when driven anywhere near what we would call 'normal'. I imagine that there are some outlets that try to wring every mile out of every gallon used, regardless of drive train (all electric, hybrid, diesel, gasoline...). Those outlets just aren't going to be nearly as popular as the Car and Drivers of the world.
When you try to sell a steak you don't sell the juice per cubic inch, you sell the sizzle. Most auto journalists are simply tuned to test the sizzle and no other metric.
I think we can all agree that to get the best mpg out of a hybrid you don't drive it like a regular car. I didn't expect to change my driving technique but after months (and over 15,000 miles) of hybrid ownership, my driving has changed dramatically. It wasn't intentional, but it increased my mpg. I'd say I'm somewhere in between the 'aggressive' driving style and the 'hypermileing' driving style. As such my average mpg is in between the C&D 32 mpg and the hypermilers that regularly get over 50 mpg.
When I shop around for a new car I'll still utilize main stream auto press and their mpg numbers. But I'll use it as a comparison against different models (say for example the Ford got 32, the Toyota got 34, the Hyundai got 27...). I won't use it as a measure of what I will get out of these vehicles, just that I should get the most out of a Toyota and the least out of a Hyundai. What I won't do is head over to the Hyundai forum and see what their owners are getting vs the Toyota forum and what their owners are getting and compare those to the Ford forum and what their owners are getting. No consistency.