United States securities and exchange commission logo
August 26, 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 the
fiscal year ended December 31, 2021
Form 8-K Furnished
August 4, 2022
File No. 001-34211
Dear Mr. Bachus:
We have limited our review of your filings 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 8-K Furnished August 4, 2022
Exhibit 99.1
2022 Outlook, page 7
1. Please present with
equal or greater prominence the respective comparable outlook GAAP
measures to the
apparent non-GAAP measures "as adjusted operating margin" and "as
adjusted diluted EPS,"
with reconciliations between the GAAP and non-GAAP measures
as appropriate. In
regards to "as adjusted diluted EPS," it appears you need to present
the non-GAAP basis for
the measure, the comparable GAAP measure to the non-GAAP
basis and
reconciliation between these two measures. Refer to Item 10(e)(1)(i)(A) and (B)
of Regulation S-K and
Question 102.10 of the staff's "Non-GAAP Financial Measures"
Compliance and
Disclosure Interpretations.
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
Daniel Bachus
Grand Canyon Education, Inc.
August 26, 2022
Page 2
absence of action by the staff.
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
August 26, 2022 Page 2 Office of Trade &
Services
FirstName LastName