In a submission to Treasury about the FSI final report, the Association of Superannuation Funds of Australia said a "comprehensive assessment of the system is required before any judgement can be made as to its efficiency".
A key recommendation of the FSI when it came to price-based competition (which it found is currently lacking) was that the superannuation sector should be reassessed in 2020 after MySuper has been 'given a chance to work'.
"However, it is critical that we begin this process of assessment early and develop a time series of data upon which to form a framework for any future review," the ASFA submission said.
ASFA proposed the idea of a scorecard that could be used for a "snapshot assessment" at points in time.
"It is a first pass at what could be some sensible measures of efficiency against which the system can be assessed," ASFA said.
The lobby group recommended the creation of a Superannuation System Review Panel to "determine the key components of industry efficiency and on this basis gather relevant data".
The industry will also be able to use the data to self-assess and improve, while public policymakers will be informed of the status of competitive forces in superannuation.
"ASFA also sees appeal in a scorecard approach as one way in which we could be monitoring performance on an ongoing basis across the various facets of the system," the submission said.
An example of the scorecard in the submission – which ASFA stressed was an incomplete draft – includes measures of the economic benefits of super such as average projected retirement incomes, a breakdown of superannuation assets and the expenditure on the age pension and tax concessions as a percentage of GDP.
When it comes to system efficiency, the scorecard measures operational efficiency across APRA-regulated funds, investment costs, insurance, regulation and "structural flexibility".
Finally, the scorecard breaks down "member experience" into average fees paid per member, net returns and services received.
