What is the test for personal infliction of great bodily injury under section 12022.7?

by any means of force likely to produce great bodily injury while confined in a state prison, with a section 12022.7 enhancement for the personal infliction of great bodily injury. "Proof that a victim's bodily injury is 'great' - that is, significant or substantial within the meaning of section 12022.7 - is commonly established by evidence of the severity of the victim's physical injury, the resulting pain, or the medical care required to treat or repair the injury. [Citations.]" (People v. Cross (2008) 45 Cal.4th 58, 66.)