dissenting.
This case is about Senior and Disabled Service Division’s interpretation of its own rule in a manner that frustrates the very purpose of the benefits that the agency *298administers. The agency denied spousal pay benefits to petitioner even though her health condition requires that her husband stay at home and care for her. Apparently, the majority’s and the agency’s decision will force her removal from her home to a nursing home to receive the care that she requires, a result that is directly contrary to the purpose underlying spousal pay benefits. I dissent because I agree with petitioner’s argument that the agency incorrectly interpreted OAR 411-30-020(14) when it ruled that petitioner does not qualify for spousal pay assistance.
To be entitled to benefits under the spousal pay program when a married recipient of public assistance requires in-home care, the recipient must require “full assistance in at least four of the six activities of daily living as determined by the assessment and would require nursing home facility placement without in-home services * * OAR 411-30-080(1)(a). OAR 411-30-020 provides, in part:
“(1) ‘Activities of Daily living’ (ADL) means those personal functional activities required by an individual for continued well-being, health and safety. This includes eating, dressing/grooming, bathing/personal hygiene, mobility, bowel and bladder management, and cognition.
“(14) ‘Full Assistance’ means the client is unable to do any part of the activity of daily living or task; i.e., it must be done entirely by someone else.”
Based on the record before it, the agency concluded that petitioner requires full assistance in only one of six activities of daily living and, therefore, she does not qualify for benefits under the spousal pay program. That conclusion, however, is inconsistent with its own findings. The agency found:
“Without Mr. Ulrich’s visible presence, Mrs. Ulrich experiences panic and becomes unable to cook, cut her food, chew or swallow. When Mr. Ulrich is present, Mrs. Ulrich can eat.
“Without Mr. Ulrich’s visible presence, Mrs. Ulrich experiences panic and becomes unable to move, organize herself or make decisions. In that way, she becomes unable to dress *299or groom herself. In Mr. Ulrich’s presence, Mrs. Ulrich can dress and groom herself.
“Without Mr. Ulrich’s visible presence, Mrs. Ulrich experiences panic and becomes unable to perform the personal tasks of bathing or personal hygiene, in that she cannot move to the bathroom or bedroom or use the sundries and instruments if she happens to be there. In his presence, Mrs. Ulrich can perform personal hygiene tasks.
“* * * Without Mr. Ulriches visible presence, Mrs. Ulrich experiences panic and becomes unable to travel between the rooms of her house. In his presence, she is capable of mobility.
“Without Mr. Ulrich’s visible presence, Mrs. Ulrich experiences panic and she often loses bowel and bladder control and is unable to move to the bathroom or use the toilet. In his presence, she can manage her bladder and bowels and use the bathroom.
“Without Mr. Ulrich’s visible presence, Mrs. Ulrich cannot think rationally, make decisions, coordinate muscle movement, distinguish between perception and imagination, orient herself to place or time, or protect herself from everyday dangers.” (Emphasis supplied.)
According to the agency, these findings demonstrate that petitioner does not need “full assistance” within the meaning of the rule because she is able to perform the ADLs “in part” when her husband is visibly present. The issue on review is whether the agency’s interpretation of its own rule as applied to the facts of this case is correct. Our standard of review is expressed in Don’t Waste Oregon Com. v. Energy Facility Siting, 320 Or 132, 142, 881 P2d 119 (1994).
“As noted, this court is authorized to overrule an agency’s interpretation of a rule if an agency has ‘erroneously interpreted a provision of law.’ ORS 183.482(8)(a). In this case, the ‘provision of law’ is the rule itself. Where, as here, the agency’s plausible interpretation of its own rule cannot be shown either to be [1] inconsistent with the wording of the rule itself, or [2] with the rule’s context, or [3] with any other source of law, there is no basis on which this court can assert that the rule has been interpreted ‘erroneously.’ ”
“Plausibility” connotes only superficial worthiness. Thus, under the above standard, the possibility that the agency’s *300interpretation of the rule is plausible does not end the inquiry. Rather, the agency’s interpretation to be upheld must be consistent with the rule’s text and context or meaning as a whole.
In that light, OAR 411-30-020(14) is intended to provide care benefits to a disabled person in the person’s home. The rule addresses the specific situation where the care provider is married to the recipient of the benefits. Read in context, the rule authorizes the payment of benefits despite the care provider’s relationship to the recipient when the recipient requires “full assistance” in at least four of the six activities of daily living and otherwise, would require nursing home facility placement. The text of the rule requires the agency to focus on what the disabled person is able to do without assistance. Whether the care provider is the spouse or a third person is irrelevant to that focus. It is only after a determination is made about what functions the disabled person is able to perform, that payment of benefits for care provided by a spouse, rather than a third person, becomes germane. Thus, “assistance” as used in the context of the rule refers to help that could be given by anyone.
In this case, the agency initially focused on what petitioner could or could not do without anyone’s assistance. According to its findings, petitioner is unable to perform the ADLs of thinking rationally, making decisions, orienting herself to time or place, eating, dressing herself, fulfilling personal hygiene tasks, moving within the area of her own house or managing her own bladder and bowels without assistance. Those are circumstances that require nursing home care and the assistance of a care provider and that implicate the need for the benefits contemplated by the rule. The rule provides a means for the spouse to act as a substitute care provider and thereby to avoid the need for nursing home care. There could be no clearer case of the need for full assistance in performing ADLs than that which petitioner presents.
Nonetheless, Agency asserts that the definition of “Full Assistance” in OAR 411-30-020(14) supports its interpretation because to qualify under the rule, a recipient must be unable to perform any part of an ADL, “i.e., it must be done entirely by someone else.” It follows, according to agency, *301that because petitioner is able to perform ADLs in her husband’s presence, she is able to perform them in part (an ability that disqualifies her under the rule). It is at that point in the analysis that the agency’s interpretation gets off track, and its interpretation of the rule becomes inconsistent with the context of the rule as a whole. In sum, the agency’s interpretation improperly changes the focus from what the client is able to do without assistance to what she is able to do when her husband is present.
The following hypothetical illustrates the point. Suppose, for example, that petitioner’s condition was such that she would be unable to perform the ADLs except in the visible presence of a third person, other than her husband. In the context of the rule, she would still require full assistance to perform the ADLs. Her condition would require either nursing home care or full home care provided by a third person. Thus, the fact that petitioner can perform ADLs in the presence of her husband rather than in the presence of someone else is of no significance in the determination of whether she meets the criteria of “full assistance.”
Similarly, the fact that petitioner can perform ADLs in the presence of her husband does not disqualify her when the context of the rule is considered. According to the rule’s text, a recipient must be unable to do any part of the ADL to qualify, i.e., the ADL must be performed entirely by someone else. In context, the disqualifying part-performance of an ADL must refer to the ability to perform those facets of the ADL that are not integral to the completion of the task. Otherwise, the purpose of the benefits is defeated. Example: if a recipient needed someone else to manually lift the eating utensil to her mouth to eat, that circumstance would satisfy the rule’s requirement. Without the assistance of the care provider, the recipient could not eat or perform the entire function. The fact that the recipient could chew or digest the food placed in her mouth would not disqualify her from benefits. On the other hand, if the disabled person could personally feed herself, that ability could disqualify her from benefits. In that light, the only reasonable interpretation of the rule is that the requirement of “full assistance” must be flexible enough to encompass any facet of the function necessary to its completion, and the inability to perform any facet that *302results in the complete impairment of the ADL qualifies the recipient as needing “full assistance.”
In this case, the presence of petitioner’s husband is even more indispensable to her ability to eat than the assistance of the care provider in the example. According to the findings, petitioner cannot chew or swallow without her husband’s presence. Presumably, she will have to be fed intravenously if placed in a nursing home in the absence of her husband’s presence. The fact that petitioner’s husband provides indispensable psychological assistance rather than physical assistance to enable her to eat is of no import under the requirements of the rule. In either case, the disabled person is unable to eat without full assistance. A similar rationale applies to the inability of petitioner to perform the other ADLs.
When an agency interprets its own rule inconsistently with the wording of the rule itself or the rule’s context, we are not obligated to adopt that interpretation. Don’t Waste Oregon Com,, 320 Or at 142. In this case, agency misinterpreted its own rule when it focused on what petitioner’s husband could do for petitioner rather than on what petitioner could do for herself in the absence of her husband or anyone else and when it adopted an interpretation that is inconsistent with the purpose of the rule. For those reasons, the majority errs when it affirms agency’s “plausible” ruling that petitioner is not entitled to spousal pay benefits under OAR 411-30-080(l)(a), and a grave injustice to petitioner and her husband results.
Accordingly, I dissent.
Warren and Armstrong, JJ., join in this dissent.