If individual NHS staff face prosecution for failing to provide care for patients it could create a "climate of fear and blame", Lord Howe said.
The health minister said he would be "nervous" about making NHS workers open to criminal sanctions for causing serious harm to patients.
He made his comments after Robert Francis QC said that public confidence in the health service would "evaporate" unless staff who seriously breach fundamental standards of patient care were made eligible for prosecution.
The chairman of the public inquiry into serious failings at Mid Staffordshire NHS Foundation Trust recommended the move as part of his final report into the scandal.
But the measure was not introduced as part of the Government's initial response to the inquiry, and ministers said they were still considering the recommendation.
Speaking at the National Institute for Health and Care Excellence (Nice) annual conference in Birmingham, Lord Howe said: "We are trying to button down at the moment where the criminal offence should fall - whether it should fall at an organisational level or on to an individual level.
"I think I am nervous about it falling on to an individual level, if I speak candidly, because it might produce a very opposite result from the one we want which is maximum openness and candour. If people were living in a climate that they perceive as a climate of fear and blame then we might not achieve what we want. We are very clear that Francis's core recommendation has to be taken forward - I think there is a criminal offence at the core of that and the Care Bill will no doubt focus on that in committee."
Mr Francis told the Health Service Journal and the Nursing Times it was "only right" for NHS workers to face criminal sanctions for "extreme" cases of poor care.
He said: "I'm talking about the sorts of behaviour we saw so many distressing examples of in Stafford. Of absolutely appalling care - insulting to human dignity and in some cases life threatening behaviour, leaving people naked, unfed, covered in faeces. These are things which everyone agrees just should never happen.
"Unless we have a criminal offence we will not be reflecting adequately the gravity of the terrible things it seems are capable of being done in our hospital wards if they are not properly run. No one liked to believe such things were possible but they are. If we don't reflect somehow the fact the public rightly think some things are terrible and there should be real accountability for them, then I believe the public confidence in the NHS will evaporate."