To examine whether special education racial risk ratios reported by U.S. school districts are explained by district-level confounds, particularly, racial achievement gaps, we analyzed merged data (N = 1,952 districts for Black-White comparisons; N = 2,571 districts for Hispanic-White comparisons) from the U.S. Department of Education's Office of Civil Rights, Stanford Educational Data Archive, and Common Core data sets. Regression analysis results indicated that Black- and Hispanic-White district risk ratios were strongly related to Black- and Hispanic-White district achievement gaps. These results reconcile findings from district-level data with those from student-level data and support the finding that, when compared to otherwise similar White students by controlling for group differences in achievement, non-White students are on average underrepresented in special education. That is, non-White overrepresentation in special education in most districts is explained by racial achievement gaps in these districts. Residuals from the regressions provide a more accurate way to monitor for outlier districts than the current practice required in federal regulations of using unadjusted risk ratios.