Ideal way to return a scalar from function (RETURN vs. SELECT)?
I'd prefer to use RETURN rather than RETURN QUERY SELECT in pl/pgsql.

But there's no need to jump through hoops. The cost of returning results with SELECT is negligible compared to other costs in pl/pgsql procedures.

Everything is a result-set in PostgreSQL anyway, even a single scalar, so you're not saving much with RETURN.