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