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February 23, 2015

United States Securities and Exchange Commission

Division of Corporation Finance

Washington, D.C. 20549-7010

Attention: Larry Spirgel, Assistant Director

 Re: DeVry Education Group Inc.

Form 10-K for the Year ended June 30, 2014

Filed August 27, 2014

Form 10-Q for the Six Months ended December
31, 2014

Filed February 5, 2015

File No. 1-13988

Dear Mr. Spirgel:

We are in receipt of your comment letter
dated February 9, 2015 to DeVry Education Group Inc. (“DeVry Group”). On behalf of DeVry Group, we have addressed your
comment letter by reproducing each comment below in bold text and providing DeVry Group’s response immediately
following. We have also provided supplemental information as requested or where we believe appropriate to the response.

Form 10-K for the Year ended June
30, 2014

Financial Aid and Financing Student
Education, page 27

 1. Refer to the table summarizing the funding source as a percentage of revenue. Please provide
us with a breakdown of the 32% tuition payments related to “Student accounts, cash payments, private scholarships, employer
and military provided tuition assistance and other” per geographical area.

DeVry Education Group •
3005 Highland Parkway • Downers Grove, IL 60515 • 630.515.7700 • devryeducationgroup.com

DeVry Group 2

DeVry Group’s Response

The following table
summarizes, by geographical area, DeVry Group’s tuition payment funding from student accounts, cash payments, private scholarships,
employer and military provided tuition assistance and other as a percentage of total revenue for fiscal year 2013 (in thousands).

    Funding Source:
    Domestic
    Brazil
    Dominica, St. Kitts and St. Maarten
    Other
    Total

    Student accounts, cash payments, private scholarships, employer and military provided tuition assistance and other
    $471,599
    $98,531
    $52,139
    $6,542
    $628,811

    % of Total Consolidated Revenue
    24.0%
    5.0%
    2.7%
    0.3%
    32.0%

Information about Particular Government
Financial Aid Programs, page 27

Information about Other Financial
Aid Programs, page 29

Brazilian Government Financial Aid
Programs, page 30

 2. We note that DeVry Brasil students are eligible for loans under Brazil’s FIES public loan
program which is financed by the Brazilian government and PROUNI, a Brazilian governmental program which provides scholarships
to a portion of the undergraduate students under certain conditions. Please tell us how these programs work, including but not
limited to:

 · criteria for the student to obtain or earn the government aid;

 · whether the institution needs to return any of the funds in the event the student withdraws
from the course;

 · whether the student is responsible for any tuition fees after withdrawal from the course

DeVry Group’s
Response

FIES (“Fundo
de Financiamento Estudantil” or “Student Financing Fund”) provides government-funded financing for students,
with DeVry Brasil paying a participation fee based on the amount of funding provided. PROUNI (“Programa Universidade para
Todos” or “University for All” Program) is a government tax program, which encourages institutions to provide
students financial assistance in the form of discounts in return for federal tax incentives.

DeVry Group
3

In response to “criteria for the student to obtain
or earn the government aid”

For the reported periods,
eligibility for FIES was based on each student’s family monthly earnings and completion of the Exame Nacional do Ensino Médio
(“ENEM”), which is a national test administered annually to high school students by the Ministério do Educação
(“MEC” or “Ministry of Education”). Effective as of January 1, 2015, FIES loan recipients must also achieve
a minimum score on the ENEM. Students with family monthly earnings up to 20 times the federal minimum wage are eligible to receive
a portion of their tuition funded by FIES.

Eligibility for PROUNI
is based on each student’s family monthly earnings. Participants in PROUNI are selected by MEC. Only students with family
monthly earnings equal to or below 1.5 times the federal minimum wage are eligible to receive 100% of their tuition discounted
through PROUNI, and only students with family monthly earnings equal to or below 3 times the federal minimum wage are eligible
to receive 50% of their tuition discounted through PROUNI.

We will revise our
future disclosures in Part 1 of the Form 10-K to clarify the PROUNI scholarship program as follows:

Brazilian Government Financial
Aid Programs

PROUNI
promotes the exchange of tuition discounts in private postsecondary education schools by granting federal tax incentives for the
participating institutions.  No funds are received by DeVry Brasil nor the student from the federal government for the tuition
discounts granted. Instead DeVry Brasil reduces income tax expense and its income tax liability for the amount of the discounts
issued. Discounts reduce tuition by either 50% or 100%. The percentage depends on a certain set of rules defined by the Brazilian
government based on family monthly earnings.

An identical
disclosure will be added to the Form 10-K and Form 10-Q MD&A Income Taxes discussions.

In response to “whether the institution
needs to return any of the funds in the event the student withdraws from the course” and “whether the student is responsible
for any tuition fees after withdrawal from the course”

These two questions are answered on
a combined basis in order to enhance the clarity of our responses.

DeVry Brasil institutions
offer classes annually through two, six-month semesters. At the beginning of each semester, students enter into enrollment contracts
with their particular DeVry Brasil institution. In accordance with these contracts, tuition is billed monthly in advance of each
month of the semester, with the payment for the first month due by the start of each semester. If a student withdraws prior to
the start of a semester, DeVry Brasil retains 20% of the first billed month’s tuition and, if paid, refunds the remaining
80% to the withdrawing student. After the start of a semester, if a student withdraws, DeVry Brasil retains 100% of the tuition
billed through the month of withdrawal and ceases billing the student for additional months of the semester.

DeVry
Group 4

FIES pays for student
accounts no earlier than 45 days after the end of the month for which a student is billed. MEC will not fund under FIES student
accounts payable for the semester if a student cancels their FIES contract at any time during that semester. If funds have already
been transferred to the institution for a student who cancels a contract, future transfers of other FIES funds will be reduced
by these previously transferred amounts. In these cases, the student becomes responsible for the outstanding balance, including
all amounts previously paid by FIES funds, attributable to the semester of withdrawal.

PROUNI is based on
tuition discounts, and no funds are received by DeVry Brasil nor the student from the federal government for the tuition discounts
granted. If a student withdraws, DeVry Brasil will adjust their future tax benefits for any previous benefits taken for the withdrawn
student. After a student withdraws, a student is only responsible for the discounted portion of their tuition billed during the
month of their withdrawal.

 3. We note that as of June 30, 2014, approximately 41% of overall DeVry Brasil’s students
financed their tuition under the FIES program while around 11% have obtained scholarships under the PROUNI program. Please tell
us how the remainder of DeVry Brasil’s students finance their tuition.

DeVry Group’s
Response

The remaining balance
of tuition and fees not covered by FIES and PROUNI programs is the responsibility of the students who pay their tuition, as they
attend classes, on a monthly basis.

 4. For each funding sources tell us how you evaluate the collectability
of revenue when a student begins attending class.

DeVry Group’s
Response

As stated above, DeVry
Brasil is remunerated for tuition revenue by three primary sources: FIES, PROUNI and student self-payments. Generally, FIES funds
are collected no earlier than 45 days after the completion of a month for which a student is billed. MEC will not fund under FIES
student accounts payable for the semester if a student cancels their FIES contract at any time during that semester. If funds have
already been transferred to the institution for a student who cancels a contract, future transfers of other FIES funds will be
reduced by these previously transferred amounts. In these cases, the student becomes responsible for the outstanding balance, including
all amounts previously paid by FIES funds, attributable to the semester of withdrawal. From time-to-time, there are some FIES funds
that may not be collected for reasons that may include canceled or suspended contracts between MEC and the student. The loss rate
on this funding is factored in the analysis of the total allowance for uncollectible accounts. PROUNI is a program which exchanges
tuition discounts for a reduction in federal taxes. There is no collectability issue with this form of student financial assistance
as the tax incentives are taken directly by the institution through a reduction of their federal tax remittances. An allowance
for uncollectable accounts is established when revenue is recognized, based on historical loss rates on collections of accounts
receivable, and revised periodically based on an analysis of the aging of accounts receivable. The provision for uncollectible
accounts from FIES and student receivables not covered by financial aid represented 3.5% and 4.1% of net revenue in fiscal years
2014 and 2013, respectively.

DeVry Group 5

Critical Accounting Policies, page
75

Revenue Recognition, page 76

 5. Refer to the last sentence in the first paragraph of page 76. You state that the provision for
refunds and the provision for uncollectible accounts are recognized in the same ratable fashion as revenue to most appropriately
match these costs with the tuition revenue in that term. Please explain to us in detail why the provision for uncollectible accounts
is recognized on the same ratable fashion as revenue. In this regard we note that this disclosure differs from similar disclosures
on page 98. Please clarify this inconsistency.

DeVry Group’s
Response

DeVry Group’s
tuition revenue is recognized ratably over the period of instruction which varies within our Title IV-eligible institutions. As
tuition and fees are billed, and revenue is recognized, a reserve for uncollectible tuition and fees is also established through
our allowance for doubtful accounts process, and we record a related charge to bad debt expense based on historical collections
experience. In addition, the allowance for uncollectible accounts is also determined by analyzing the current aging of accounts
receivable, projections of future receivable levels and historical collections experience. We review this analysis on a monthly
basis for each institution and adjust the provision for uncollectible accounts accordingly. To clarify, we are matching the provision
for uncollectible accounts with the revenue generated in the period along with recording expense for changes in the status of receivable
balances, some of which were initially recorded in prior terms. We will revise our future disclosures in the MD&A to be consistent
with that in the disclosure on page 98 which states in part:

The
provision for refunds, which is reported as a reduction to Tuition Revenue in the Consolidated Statements of Income, is recognized
in the same ratable fashion as revenue to most appropriately match these costs with the tuition revenue in that term.

This disclosure eliminates
the reference to the allowance for uncollectable accounts that appears in the MD&A on page 76.

DeVry Group 6

Consolidated Statement of Cash Flows,
page 93

 6. Please refer to the line item “Provision for Refunds and
Uncollectible Accounts”. It is unclear to us why refunds are shown as a reconciling item in the statement of cash flows.
Please revise or advise.

DeVry Group’s
Response

The provision for
refunds is recorded as a reduction to revenue in the period that the tuition is earned, is a non-cash charge and, therefore, is
included as a reconciling item in the Consolidated Statements of Cash Flows. The cash effect of the refunds is reported with the
change in the net accounts receivable balance for the period under the “Changes in Assets and Liabilities, Net of Effects
from Acquisition and Divestiture of Components” section of the Consolidated Statement of Cash Flows. Refunds are charged
as a reduction of revenue based on historical refund rates in the same ratable fashion as revenue is earned. This may not match
the actual payment of refunds.

Note 3 – Summary of Significant
Accounting Policies, page 97

Revenue Recognition, page 98

 7. We note that the majority of your students fund their education
through loans and/or grants received from U.S. federal financial aid programs established by Title IV of the Higher Education Act
and regulations promulgated thereunder (“Title IV”). We understand that when a student, who has received Federal Student
Aid, withdraws from the University prior to completing a course or payment period, the University may have a return to Title IV
requirement. You state that if a student leaves school prior to completing a term, federal, state, and/or
Canadian provincial regulations and accreditation criteria permit DeVry Group to retain only a set percentage of the total tuition
received from such student, which varies with, but generally equals or exceeds, the percentage of the term completed by such student.
Further you state payment amounts received by DeVry Group in excess of such set percentages of tuition are refunded to the student
or the appropriate funding source.

To help us better understand
your accounting policy; please provide us with the following information:

 · tell us how you determine that a student has withdrawn;

 · tell us if you reassess collectability of tuition and fees when a student withdraws from a course,
the institution, or otherwise loses Title IV eligibility;

 · tell us about your historical collections experience with students who become responsible for
tuition and related fees due to withdrawal or loss of financial aid eligibility; and

 · tell us under what circumstances the accreditation criteria allows
you to retain amounts in excess of the set percentage of tuition.

DeVry Group 7

In response to “Tell us how you determine that
a student has withdrawn”;

We are able to determine
that a student has withdrawn from either direct communication from the student informing us of his or her intent to withdraw or
from a cessation in attendance or participation in the student’s courses. Students may voluntarily withdraw from a course
or their program by notifying the designated office or official within each institution. Students may be administratively withdrawn
from a course or program if they cease attending on-site classes or participating in on-line classes. Minimum attendance and participation
standards are established within each of our institutions. Typically these standards require at least three substantive postings
per week in on-line classes and no more than seven consecutive days of non-attendance in on-site classes. These standards are published
in the institutions’ academic catalogs and student handbooks. Adherence to these standards is monitored by institution personnel
and systems. Students who are subject to administrative withdrawal are promptly notified when attendance and participation standards
have been violated. Students are permitted seven days to appeal the pending withdrawal action. Students with denied appeals or
who fail to appeal are then administratively withdrawn. The withd