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United States securities and exchange commission logo
May 19, 2020
Daniel E. Bachus
Chief Financial Officer
Grand Canyon Education, Inc.
2600 W. Camelback Road
Phoenix, Arizona 85017
Re: Grand Canyon
Education, Inc.
Form 10-K for the
Fiscal Year Ended December 31, 2019
Filed February 20,
2020
Form 10-Q for the
Interim Period Ended March 31, 2020
Filed May 7, 2020
File No. 001-34211
Dear Mr. Bachus:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comments. In some of our comments, we
may ask you to
provide us with information so we may better understand your disclosure.
Please respond to these comments within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe our
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to these comments, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2019
Liquidity, Capital Resources, and Financial Position
Cash Flows
Operating Activities, page 51
1. It appears from the
statement of cash flows changes in assets and liabilities, which
includes working
capital items, between 2019 and 2018 of $101.6 million is the
substantial cause of
the $107.3 million, or 54%, increase in 2019 operating cash flows
compared to 2018.
Please revise your disclosure to discuss the material items and
the associated
underlying factors contributing to the variance. Refer to IV.B.1 of SEC
Release No. 33-8350 for
guidance. Quantify any factors cited, pursuant to section 501.04
of the staff's
Codification of Financial Reporting. Additionally, define what you consider
to be your working
capital.
Daniel E. Bachus
Grand Canyon Education, Inc.
May 19, 2020
Page 2
Form 10-Q for the Interim Period Ended March 31, 2020
Notes to the Consolidated Financial Statements
Revenue Recognition, page 13
2. It appears from your disclosures you generate service revenue from two
primary sources -
GCU and Orbis. You disclose that GCU is your most significant
university partner for
which a reduction of revenue would have a material impact on your
consolidated
revenues, operating income and margins. Other disclosures also note
various factors
affecting the timing and relative amount of revenue recognized between
these sources. In your Q1 2020 earnings call you highlight certain
aspects of each of these
sources of revenue, for example Orbis's revenue growth percentage,
adjusting revenue and
earnings guidance due to the lower anticipated revenue on the GCU
contract, reduced
revenue from other university partners (presumably generated through
Orbis), and your
percentage share of ancillary revenues, including room and board,
associated with GCU.
In view of the preceding, please explain to us your consideration of
presenting
disaggregated revenue for the aforementioned sources or other sources
as appropriate
pursuant to ASC 606-10-50-5 to enable users to understand the nature,
amount, timing,
and uncertainty of your revenue and cash flows arising from your
contracts with
customers.
In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.
You may contact Theresa Brillant at 202-551-3307 or Doug Jones at
202-551-3309 with
any questions.
FirstName LastNameDaniel E. Bachus Sincerely,
Comapany NameGrand Canyon Education, Inc.
Division of
Corporation Finance
May 19, 2020 Page 2 Office of Trade &
Services
FirstName LastName