United States securities and exchange commission logo
September 22, 2022
Daniel Bachus
Chief Financial Officer
Grand Canyon Education, Inc.
2600 W. Camelback Road
Phoenix AZ 85017
Re: Grand Canyon
Education, Inc.
Form 10-K for
Fiscal Year Ended December 31, 2021
Form 8-K Furnished
August 4, 2022
Response dated
September 9, 2022
File No. 001-34211
Dear Mr. Bachus:
We have reviewed your September 9, 2022 response to our comment
letter and have the
following comment. Our comment, ask you to provide us with information
so we may better
understand your disclosure.
Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your response to this comment, we may have
additional
comments. Unless we note otherwise, our references to prior comments are
to comments in our
August 26, 2022 letter.
Response dated September 9, 2022
Form 8-K Furnished August 4, 2022
Exhibit 99.1
2022 Outlook, page 7
1. Your proposed narrative
description of the calculation of the non-GAAP measures "as
adjusted operating
margin" and "as adjusted diluted EPS" does not appear to provide
investors with enough
information to reconcile to the comparable GAAP
measures without
unreasonable effort. In this regard, please consider providing a
schedule for the
reconciliation.
Daniel Bachus
Grand Canyon Education, Inc.
September 22, 2022
Page 2
You may contact Patrick Kuhn at (202) 551-3308 or Doug Jones at (202)
551-3309 with
any questions.
FirstName LastNameDaniel Bachus Sincerely,
Comapany NameGrand Canyon Education, Inc.
Division of Corporation
Finance
September 22, 2022 Page 2 Office of Trade &
Services
FirstName LastName