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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

 FirstName LastNameDaniel Bachus
 Comapany NameGrand Canyon Education, Inc.
 August 26, 2022 Page 2
 FirstName LastName
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.
Sincerely,
Division of Corporation Finance
Office of Trade & Services