The comments came as the DoH launched a consultation on regulations to define the role of responsible officers, the senior doctors who will act as a link between local healthcare organisations and the GMC.
The vast majority of responsible officers are expected to be PCO medical directors.
But Dr Stephanie Bown, director of policy and communications at the Medical Protection Society, said: 'I think there is the potential for an inherent conflict of interest between being responsible for referring people to the GMC and (medical directors') clinical governance responsibility, in which they have to encourage openness.'
Dr Bown pointed out that around 600 NHS organisations will need a responsible officer, and warned that it would be difficult to find enough people with the 'level of competency to make it successful'.
She said the scale of the role was likely to vary hugely, depending on the size of each NHS organisation. Medical directors already faced heavy workloads, and those in large trusts might be unable to cope with the additional work, she warned.
Dr Bown also said the wording of parts of the guidance for responsible officers was a concern. She pointed out that where conflict arose between a GP and the responsible officer, the guidance said mediation by a second responsible officer 'may' be available. This was too woolly, she argued.
In addition, wording of the guidance appeared to suggest that different responsible officers would operate to different standards, she said.
Dr Bown added that the person specification for responsible officers was 'unbelievably broad and aspiratrional'.
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