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An audit response is not necessarily (so can be) a substantive procedure. See any examiner’s report https://www.accaglobal.com/uk/en/student/exam-support-resources/fundamentals-exams-study-resources/f8/examiners-reports.html for further details.
A test of controls is unlikely since, by definition, the auditor must expect good controls (i.e. low control risk) in order to seek to rely on the effective operation of controls and so reduce the extent of substantive procedures.
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