This analysis provides an update of the national incidence data for "504-only" students, that is, students who are not eligible under the Individuals With Disabilities Education Act but are eligible under the broader definition of disability in Section 504 of the Rehabilitation Act, as amended by the Americans With Disabilities Act of 2008. More specifically, this article analyzes the data for 504-only students overall and for selected student and school characteristics based on the 2011–2012 Civil Rights Data Collection (CRDC) and compares the results with the parallel analysis of the 2009–2010 CRDC. The findings include a national incidence of 1.48%, as compared with 1.02% for 2009–2010, and continuing notable difference for student race/ethnicity and gender, and for school Title I status. However, the more recent data do not show a notable difference between the percentages of 504-only students in charter and non-charter schools. The discussion includes research as well as policy considerations.