Below is a link that will show you what a basic 220V heater looks like, each lead to it is 110V (positive and negative) in order for a heater to function it has to have resistance to it, while grounding it would work it would destroy any function your GFCI serves and would not protect you if the heater were to burst open and allow electricity into the water (we're cooking now) there are almost never two elements and if there were then it would have 4 leads going to it and not just two. In order for ANY circuit to function it has to loop through and have some sort of resistance between the two sides.
http://spapartsnet.com/p_Heater-Element ... 6_0_1.html