It's possible, though the only resemblance to Alayaya would be her being beaten. Shae is already inside the castle as Sansa's hand maid, and Cersei "catching" Tyrion with Ros could easily be explained truthfully as him visiting her because he paid her to visit Joffrey. Also it was Varys who helped orchestrate Tyrion's secret get togethers, Littlefinger owns Ros' brothel. Ros taking a beating because Cersei believes it will hurt Tyrion when Ros has no idea why she is being punished, is not the same as Alayaya knowingly helping Tyrion and getting punished for it while protecting Tyrion and Shae.
The Alayaya substitution would have made more sense if they had kept Tyrion sneaking around to see Shae, but so far he has already had her in his room in the Tower of the Hand (where he comments how Ned slept on this bed to her), and despite his comments that he wants to keep her hidden from the queen, we have seen no evidence of him sneaking around to see her so far. Certainly they COULD rewrite the story so that she is necessary again, but why move up Shae becoming Sansa's handmaid, instead of sticking closer to the original plot and having Tyrion have to sneak thru the brothel secret passages? They also have not given any clues to the secret tunnels inside the Red Keep yet. Ros has had an awful lot of scenes setting her up, if her only resemblance to Alayaya is to take a beating from Cersei.
I forgot to mentioned that Tyrion would be visiting Ros to inquire about what happened with Joffrey (or something along those lines), but Cersei wouldn't realize that (as you already mentioned; Ros isn't as complicit as Alayaya had been in the novels). But again, this is an adaptation of the novels, so it may play out a bit differently while retaining the same function to the plot. If anything, I think this makes the most sense both from an economical storytelling stand-point, and from how Ros has been developed throughout the course of this season. A lot of people have mentioned that Ros may have gained weight or that she may be pregnant, which is why we haven't seen her portrayed as she was last season for the most part (i.e.
naked). I'm of the thinking that she's kept her clothes on so the audience is more easily able to focus on her as a character, and provide a bit more legitimacy when she's taken by Cersei (or whatever ends up happening).
Ros a Jeyne Poole on the other hand... Incredibly stupid (no offense meant, but it is dumb).