Targeted maximum likelihood estimation (TMLE) in regulatory submissions and research: a landscape analysis

Targeted Maximum Likelihood Estimation, also referred to as Targeted Minimum Loss Estimation (TMLE), is a statistical method that enables causal inference while incorporating flexible, advanced machine learning techniques. Within the drug development space, both drug sponsors and FDA have leveraged TMLE across a range of relevant clinical settings intended for a variety of regulatory activities. The goal of this article is to provide a holistic overview of TMLE use cases as they have been applied in submissions to the Food and Drug Administration (FDA) Center for Drug Evaluation and Research (CDER) and in CDER's regulatory research activities. First, we provide an overview of regulatory submissions in which TMLE has been considered to support regulatory decision-making. Second, we summarize FDA CDER's regulatory science initiatives that advance analytic capabilities and support the use of TMLE.